"Fusion GPS is proud of the work it has conducted and stands by it," Levy, Simpson's lawyer, said in a statement.

He said the "investigation into Mr. Simpson began as a desperate attempt by the Trump campaign and its allies to smear Fusion GPS because of its reported connection to the Trump dossier."

Committee Hears From Founder of Firm Tied to Trump DossierThe co-founder of a Washington opposition research firm that produced a dossier of salacious allegations involving President Donald Trump met for hours with congressional investigators Tuesday in a closed-door appearance that spanned into the evening.

Aug. 22, 2017, at 8:47 p.m.

Committee Hears From Founder of Firm Tied to Trump Dossier

By ERIC TUCKER, Associated Press

WASHINGTON (AP) — The co-founder of a Washington opposition research firm that produced a dossier of salacious allegations involving President Donald Trump met for hours with congressional investigators Tuesday in a closed-door appearance that spanned into the evening.

Glenn Simpson's lawyer emerged from the daylong private appearance and said his client had "told Congress the truth and cleared the record on many matters of interest."

The lawyer, Josh Levy, noted that Simpson appeared voluntarily and has so far been the only witness to be interviewed by the Senate Judiciary Committee as it looks into Russian interference in the 2016 presidential election.

The sheer length of Simpson's appearance — far longer, for instance, than Trump's son-in-law spent earlier this summer with Senate and House intelligence committees — reflected the intrigue on Capitol Hill surrounding the dossier and the origins of the document.

Simpson's firm, Fusion GPS, hired a British intelligence officer who produced a dossier containing allegations of ties between Trump and his associates and Russia. Simpson kept the identities of the firm's clients confidential during his appearance before Congress, his lawyer said.

The document attracted public attention in January when it was revealed that FBI Director James Comey had briefed Trump about its existence soon before he was inaugurated as president. It's unclear to what extent the allegations in the dossier have been corroborated or verified by the FBI since the bureau has not publicly discussed it.

"Fusion GPS is proud of the work it has conducted and stands by it," Levy, Simpson's lawyer, said in a statement.

He said the "investigation into Mr. Simpson began as a desperate attempt by the Trump campaign and its allies to smear Fusion GPS because of its reported connection to the Trump dossier."

Leaders of the Judiciary Committee said last month that they were negotiating private appearances for Donald Trump Jr., who has attracted scrutiny for accepting a June 2016 meeting with Russians at which he expected to receive damaging information about Hillary Clinton, and for Paul Manafort, the former Trump campaign chairman. Yet no dates have been announced for their appearances.

"Following up on comments from certain Senate Judiciary Committee members who have noted Mr. Simpson's cooperation with this investigation," Levy said, I would like to add that he is the first and only witness to participate in an interview with the Committee as it probes Russian interference in the 2016 election."

[Editor’s Note: In this special Just Security article, highly respected former member of the CIA’s Senior Intelligence Service, John Sipher examines the Steele dossier using methods that an intelligence officer would to try to validate such information. Sipher concludes that the dossier’s information on campaign collusion is generally credible when measured against standard Russian intelligence practices, events subsequent to Steele’s reporting, and information that has become available in the nine months since Steele’s final report. The dossier, in Sipher’s view, is not without fault, including factual inaccuracies. Those errors, however, do not detract from an overarching framework that has proven to be ever more reliable as new revelations about potential Trump campaign collusion with the Kremlin and its affiliates has come to light in the nine months since Steele submitted his final report.]

Recent revelations of Trump campaign connections to Russia have revived interest in the so-called Steele Dossier. The dossier is composed of a batch of short reports produced between June and December 2016 by Orbis Business Intelligence, a London-based firm specializing in commercial intelligence for government and private-sector clients. The collection of Orbis reports caused an uproar when it was published online by the US website BuzzFeed, just ten days before Donald Trump’s inauguration. Taken together, the series of reports painted a picture of active collusion between the Kremlin and key Trump campaign officials based on years of Russian intelligence work against Trump and some of his associates. This seemed to complement general statements from US intelligence officials about Russia’s active efforts to undermine the US election. The greatest attention was paid to the first report, which conveyed salacious claims about Trump consorting with prostitutes in Moscow in 2013. Trump himself publicly refuted the story, while Trump associates denied reported details about their engagement with Russian officials. A lot of ink and pixels were also spent on the question whether it was appropriate for the media to publish the dossier. The furor quickly passed, the next news cycle came, and the American media has been largely reluctant to revisit the report over the months since.

Almost immediately after the dossier was leaked, media outlets and commentators pointed out that the material was unproven. News editors affixed the terms “unverified” and “unsubstantiated” to all discussion of the issue in the responsible media. Political supporters of President Trump simply tagged it as “fake news.” Riding that wave, even legendary Washington Post reported Bob Woodward characterized the report as “garbage.”

For professional investigators, however, the dossier is by no means a useless document. Although the reports were produced episodically, almost erratically, over a five-month period, they present a coherent narrative of collusion between the Kremlin and the Trump campaign. As a result, they offer an overarching framework for what might have happened based on individuals on the Russian side who claimed to have insight into Moscow’s goals and operational tactics. Until we have another more credible narrative, we should do all we can to examine closely and confirm or dispute the reports.

Many of my former CIA colleagues have taken the Orbis reports seriously since they were first published. This is not because they are not fond of Trump (and many admittedly are not), but because they understand the potential plausibility of the reports’ overall narrative based on their experienced understanding of both Russian methods, and the nature of raw intelligence reporting. Immediately following the BuzzFeed leak, one of my closest former CIA colleagues told me that he recognized the reports as the obvious product of a former Secret Intelligence Service (SIS) officer, since the format, structure, and language mirrored what he had seen over a career of reading SIS reports provided to CIA in liaison channels. He and others withheld judgment about the veracity of the reports, but for the reasons I outline further below they did not reject them out of hand. In fact, they were more inclined for professional reasons to put them in the “trust but verify” category.

So how should we unpack the so-called Steele dossier from an intelligence perspective?

I spent almost thirty years producing what CIA calls “raw reporting” from human agents. At heart, this is what Orbis did. They were not producing finished analysis, but were passing on to a client distilled reporting that they had obtained in response to specific questions. The difference is crucial, for it is the one that American journalists routinely fail to understand. When disseminating a raw intelligence report, an intelligence agency is not vouching for the accuracy of the information provided by the report’s sources and/or subsources. Rather it is claiming that it has made strenuous efforts to validate that it is reporting accurately what the sources/subsources claim has happened. The onus for sorting out the veracity and for putting the reporting in context against other reporting – which may confirm or deny the new report – rests with the intelligence community’s professional analytic cadre. In the case of the dossier, Orbis was not saying that everything that it reported was accurate, but that it had made a good-faith effort to pass along faithfully what its identified insiders said was accurate. This is routine in the intelligence business. And this form of reporting is often a critical product in putting together more final intelligence assessments.

In this sense, the so-called Steele dossier is not a dossier at all. A dossier suggests a summary or case history. Mr. Steele’s product is not a report delivered with a bow at the end of an investigation. Instead, it is a series of contemporaneous raw reports that do not have the benefit of hindsight. Among the unnamed sources are “a senior Russian foreign ministry official,” “a former top-level intelligence officer still active inside the Kremlin,” and “a close associate of Republican U.S. presidential candidate Donald Trump.” Thus, the reports are not an attempt to connect the dots, but instead an effort to uncover new and potentially relevant dots in the first place.

What’s most relevant in the Orbis reports?

Let me illustrate what the reports contain by unpacking the first and most notorious of the seventeen Orbis reports, and then move to some of the other ones. The first 2 ½ page report was dated June 20, 206 and entitled “Company Intelligence Report 2016/080.” It starts with several summary bullets, and continues with additional detail attributed to sources A-E and G (there may be a source F but part of the report is blacked out). The report makes a number of explosive claims, all of which at the time of the report were unknown to the public.

Among other assertions, three sources in the Orbis report describe a multi-year effort by Russian authorities to cultivate, support and assist Donald Trump. According to the account, the Kremlin provided Trump with intelligence on his political primary opponents and access to potential business deals in Russia. Perhaps more importantly, Russia had offered to provide potentially compromising material on Hillary Clinton, consisting of bugged conversations during her travels to Russia, and evidence of her viewpoints that contradicted her public positions on various issues.

The report also alleged that the internal Russian intelligence service (FSB) had developed potentially compromising material on Trump, to include details of “perverted sexual acts” which were arranged and monitored by the FSB. Specifically, the compromising material, according to this entry in the report, included an occasion when Trump hired the presidential suite at a top Moscow hotel which had hosted President and Mrs. Obama, and employed prostitutes to defile the bed where the President had slept. Four separate sources also described “unorthodox” and embarrassing behavior by Trump over the years that the FSB believed could be used to blackmail the then presidential candidate.

The report stated that Russian President Putin was supportive of the effort to cultivate Trump, and the primary aim was to sow discord and disunity within the U.S. and the West. The dossier of FSB-collected information on Hillary Clinton was managed by Kremlin chief spokesman Dimitry Peskov.

Subsequent reports provide additional detail about the conspiracy, which includes information about cyber-attacks against the U.S. They allege that Paul Manafort managed the conspiracy to exploit political information on Hillary Clinton in return for information on Russian oligarchs outside Russia, and an agreement to “sideline” Ukraine as a campaign issue. Trump campaign operative Carter Page is also said to have played a role in shuttling information to Moscow, while Trump’s personal lawyer, Michael Cohen, reportedly took over efforts after Manafort left the campaign, personally providing cash payments for Russian hackers. In one account, Putin and his aides expressed concern over kick-backs of cash to Manafort from former Ukrainian President Viktor Yanukovych, which they feared might be discoverable by U.S. authorities. The Kremlin also feared that the U.S. might stumble onto the conspiracy through the actions of a Russian diplomat in Washington, Mikhail Kalugin, and therefore had him withdrawn, according to the reports.

By late fall 2016, the Orbis team reported that a Russian-supported company had been “using botnets and porn traffic to transmit viruses, plant bugs, steal data and conduct ‘altering operations’ against the Democratic Party leadership.” Hackers recruited by the FSB under duress were involved in the operations. According to the report, Carter Page insisted that payments be made quickly and discreetly, and that cyber operators should go to ground and cover their tracks.

Assessing the Orbis reports

What should be made of these leaked reports with unnamed sources on issues that were deliberately concealed by the participants? Honest media outlets have reported on subsequent events that appear to be connected to the reports, but do not go too far with their analysis, concluding still that the dossier is unverified. Almost no outlets have reported on the salacious sexual allegations, leaving the public with very little sense as to whether the dossier is true, false, important or unimportant in that respect.

While the reluctance of the media to speculate as to the value of the report is understandable, professional intelligence analysts and investigators do not have the luxury of simply dismissing the information. They instead need to do all they can to put it into context, determine what appears credible, and openly acknowledge the gaps in understanding so that collectors can seek additional information that might help make sense of the charges.

Step One: Source Validation

In the intelligence world, we always begin with source validation, focusing on what intelligence professionals call “the chain of acquisition.” In this case we would look for detailed information on (in this order) Orbis, Steele, his means of collection (e.g., who was working for him in collecting information), his sources, their sub-sources (witting or unwitting), and the actual people, organizations and issues being reported on.

Intelligence methodology presumes that perfect information is never available, and that the vetting process involves cross-checking both the source of the information as well as the information itself. There is a saying among spy handlers, “vet the source first before attempting to vet the source’s information.” Information from human sources (the spies themselves) is dependent on their distinct access to information, and every source has a particular lens. Professional collectors and debriefing experts do not elicit information from a source outside of the source’s area of specific access. They also understand that inaccuracies are inevitable, even if the source is not trying to mislead. The intelligence process is built upon a feedback cycle that corroborates what it can, and then goes back to gather additional information to help build confidence in the assessment. The process is dispassionate, unemotional, professional and never ending.

Faced with the raw reports in the Orbis document, how might an intelligence professional approach the jumble of information?

The first thing to examine is Christopher Steele, the author of the reports, and his organization Orbis International. Are they credible?

Steele was the President of the Cambridge Union at university, and was a career British intelligence officer with service in Moscow, Paris and Afghanistan prior to work as the head of the Russia desk at British intelligence HQS. While in London he worked as the personal handler of Russian defector Alexander Litvinenko. He was a respected professional who had success in some of the most difficult intelligence environments. He retired from SIS in 2009 and started Orbis Business Intelligence along with a former colleague. Prior to his work on the Russian dossier for Orbis, he was best known for his investigation of the world soccer association (FIFA), which provided direct support to the FBI’s successful corruption case. Steele and Orbis were also known for assisting various European countries in understanding Russian efforts to meddle in their affairs.

Like any private firm, Orbis’ ability to remain in business relies on its track record of credibility. Success for Steele and his colleagues depends on his integrity, reliability, and the firm’s reputation for serious work. In this regard, Steele is putting his reputation and his company’s continued existence on the line with each report. Yes, as with anyone operating in the murky world of intelligence, he could be duped. Nonetheless, his reputation for handling sensitive Russian espionage operations over the years suggests that he is security conscious and aware of Russian counterintelligence and disinformation efforts. His willingness to share his work with professional investigative agencies such as the FBI and the British Security Service also suggest that he is comfortable opening his work to scrutiny, and is seen as a serious partner by the best in the business.

The biggest problem with confirming the details of the Steele “dossier” is obvious: we do not know his sources, other than via the short descriptions in the reports. In CIA’s clandestine service, we spent by far the bulk of our work finding, recruiting and validating sources. Before we would ever consider disseminating an intelligence report, we would move heaven and earth to understand the access, reliability, trustworthiness, motivation and dependability of our source. We believe it is critical to validate the source before we can validate the reliability of the source’s information. How does the source know about what he/she is reporting? How did the source get the information? Who are his/her sub-sources? What do we know about the sub-sources? Why is the source sharing the information? Is the source a serious person who has taken appropriate measures to protect their efforts?

One clue as to the credibility of the sources in these reports is that Steele shared them with the FBI. The fact that the FBI reportedly sought to work with him and to pay him to develop additional information on the sources suggest that at least some of them were worth taking seriously. At the very least, the FBI will be able to validate the credibility of the sources, and therefore better judge the information. As one recently retired senior intelligence officer with deep experience in espionage investigations quipped, “I assign more credence to the Steele report knowing that the FBI paid him for his research. From my experience, there is nobody more miserly than the FBI. If they were willing to pay Mr. Steele, they must have seen something of real value.”

Step Two: Assessing the Substantive Content

As outsiders without the investigative tools available to the FBI, we can only look at the information and determine if it makes sense given subsequent events and the revelation of additional information. Mr. Steele did not have the benefit of knowing Mr. Trump would win the election or how events might play out. In this regard, does any of the information we have learned since June 2016 assign greater or less credibility to the information? Were the people mentioned in the report real? Were their affiliations correct? Did any of the activities reported happen as predicted?

To a large extent, yes.

The most obvious occurrence that could not have been known to Orbis in June 2016, but shines bright in retrospect is the fact that Russia undertook a coordinated and massive effort to disrupt the 2016 U.S. election to help Donald Trump, as the U.S. intelligence community itself later concluded. Well before any public knowledge of these events, the Orbis report identified multiple elements of the Russian operation including a cyber campaign, leaked documents related to Hillary Clinton, and meetings with Paul Manafort and other Trump affiliates to discuss the receipt of stolen documents. Mr. Steele could not have known that the Russians stole information on Hillary Clinton, or that they were considering means to weaponize them in the U.S. election, all of which turned out to be stunningly accurate. The U.S. government only published its conclusions in January 2017, with an assessment of some elements in October 2016. It was also apparently news to investigators when the New York Times in July 2017 published Don Jr’s emails arranging for the receipt of information held by the Russians about Hillary Clinton. How could Steele and Orbis know in June 2016 that the Russians were working actively to elect Donald Trump and damage Hillary Clinton? How could Steele and Orbis have known about the Russian overtures to the Trump Team involving derogatory information on Clinton?

We have also subsequently learned of Trump’s long-standing interest in, and experience with Russia and Russians. A February 2017 New York Times article reported that phone records and intercepted calls show that members of Trump’s campaign and other Trump associates had repeated contacts with senior Russian officials in the year before the election. The New York Times article was also corroborated by CNN and Reuters independent reports. And even Russian officials have acknowledged some of these and other repeated contacts. Although Trump has denied the connections, numerous credible reports suggest that both he and Manafort have long-standing relationships with Russians, and pro-Putin groups. In August 2017, CNN reported on “intercepted communications that US intelligence agencies collected among suspected Russian operatives discussing their efforts to work with Manafort…to coordinate information that could damage Hillary Clinton’s election prospects” including “conversations with Manafort, encouraging help from the Russians.”

We learned that when Carter Page traveled to Moscow in July 2016, he met with close Putin ally and Chairman of the Russian state oil company, Igor Sechin. A later Steele report also claimed that he met with Parliamentary Secretary Igor Divyekin while in Moscow. Renowned investigative journalist Michael Isikoff reported in September 2016 that U.S. intelligence sources confirmed that Page met with both Sechin and Divyekin during his July trip to Russia. What’s more, the Justice Department obtained a wiretap in summer 2016 on Page after satisfying a court that there was sufficient evidence to show Page was operating as a Russian agent.

While the Orbis team had no way to know it, subsequent reports from U.S. officials confirmed that Washington-based diplomat Mikhail Kalugin was an undercover intelligence officer and was pulled out of the Embassy and sent home in summer 2016.

The Orbis documents refer repeatedly to Paul Manafort’s “off-the-books” payments from ousted Ukrainian President Viktor Yanukovych’s pro-Russian party, and Russian concerns that it may be a vulnerability that could jeopardize the effort. According to the Orbis report, the Russians were concerned about “further scandals involving Manafort’s commercial and political role in Russia/Ukraine.” And, indeed, there have been further scandals since the Orbis reports were written. Those include Manafort being compelled in June 2017 to register retroactively as a foreign agent of a pro-Russian political parties in Ukraine, and Mueller and New York Attorney Generals’ reported investigation of Manafort for possible money laundering and tax evasion linked to Ukrainian ventures.

We do not have any reporting that implicates Michael Cohen in meetings with Russians as outlined in the dossier. However, recent revelations indicate his long-standing relationships with key Russian and Ukrainian interlocutors, and highlight his role in a previously hidden effort to build a Trump tower in Moscow. During the campaign, those efforts included email exchanges with Trump associate Felix Sater explicitly referring to getting Putin’s circle involved and helping Trump get elected.

Further, the Trump Administration’s effort lift sanctions on Russia immediately following the inauguration seems to mirror Orbis reporting related to Mr. Cohen’s promises to Russia, as reported in the Orbis documents. A June 2017 Yahoo News article by Michael Isikoff described the Administration’s efforts to engage the State Department about lifting sanctions “almost as soon as they took office.” Their efforts were halted by State Department officials and members of Congress. Following the inauguration, Cohen was involved, again with Felix Sater, to engage in back-channel negotiations seeking a means to lift sanctions via a semi-developed Russian-Ukrainian plan (which also included the hand delivery of derogatory information on Ukrainian leaders) also fits with Orbis reporting related to Cohen.

The quid pro quo as alleged in the dossier was for the Trump team to “sideline” the Ukrainian issue in the campaign. We learned subsequently the Trump platform committee changed only a single plank in the 60-page Republican platform prior to the Republican convention. Of the hundreds of Republican positions and proposals, they altered only the single sentence that called for maintaining or increasing sanctions against Russia, increasing aid for Ukraine and “providing lethal defensive weapons” to the Ukrainian military. The Trump team changed the wording to the more benign, “appropriate assistance.”

Consider, in addition, the Orbis report saying that Russia was utilizing hackers to influence voters and referring to payments to “hackers who had worked in Europe under Kremlin direction against the Clinton campaign.” A January 2017 Stanford study found that “fabricated stories favoring Donald Trump were shared a total of 30 million times, nearly quadruple the number of pro-Hillary Clinton shares leading up to the election.” Also, in November, researchers at Oxford University published a report based on analysis of 19.4 million Twitter posts from early November prior to the election. The report found that an “automated army of pro-Trump chatbots overwhelmed Clinton bots five to one in the days leading up to the presidential election.” In March 2017, former FBI agent Clint Watts told Congress about websites involved in the Russian disinformation campaign “some of which mysteriously operate from Eastern Europe and are curiously led by pro-Russian editors of unknown financing.”

The Orbis report also refers specifically to the aim of the Russian influence campaign “to swing supporters of Bernie Sanders away from Hillary Clinton and across to Trump,” based on information given to Steele in early August 2016. It was not until March 2017, however, that former director of the National Security Agency, retired Gen. Keith Alexander in Senate testimony said of the Russian influence campaign, “what they were trying to do is to drive a wedge within the Democratic Party between the Clinton group and the Sanders group.” A March 2017 news report also detailed that Sanders supporter’s social media sites were infiltrated by fake news, originating from “dubious websites and posters linked back to Eastern Europe,” that tried to shift them against Clinton during the general election. John Mattes, a former Senate investigator who helped run the online campaign for Sanders, said he was struck by Steele’s report. Mattes said, Steele “was writing in real time about things I was seeing happening in August, but I couldn’t articulate until September.” It is important to emphasize here that Steele’s source for the change in plan was “an ethnic Russian associate of Republican US presidential candidate Donald Trump [who] discussed the reaction inside his camp.”

A slew of other revelations has directly tied many of the key players in the Trump campaign – most notably Paul Manafort, Carter Page, Michael Cohen, and Michael Flynn – who are specifically mentioned in the Orbis reports to Russian officials also mentioned in the reports. To take one example, the first report says that Kremlin spokesman Dmitry Peskov was responsible for Russia’s compromising materials on Hillary Clinton, and now we have reports that Michael Cohen had contacted Peskov directly in January 2016 seeking help with a Trump business deal in Moscow (after Cohen received the email from Trump business associate Felix Sater saying “Our boy can become president of the USA and we can engineer it. I will get all of Putins team to buy in on this.”). To take another example, the third Orbis report says that Trump campaign manager Paul Manafort was managing the connection with the Kremlin, and we now know that he was present at the June 9 2016 meeting with Donald Trump, Jr., Russian lawyer Natalia Veselnitskaya and Rinat Akhmetshin, who has reportedly boasted of his ties to ties and experience in Soviet intelligence and counterintelligence. According to a recent New York Times story, “Akhmetshin told journalists that he was a longtime acquaintance of Paul J. Manafort.”

The Orbis reports chronicle, and subsequent events demonstrate, that the Russian effort evolved over time, adapting to changing circumstances. When their attack seemed to be having an effect, they doubled down, and when it looked like negative media attention was benefiting Ms. Clinton, they changed tactics. The Orbis reports detail internal Kremlin frictions between the participants as the summer wore on. If the dossier is to be believed, the Russian effort may well have started as an anti-Clinton operation, and only became combined with the separate effort to cultivate the Trump team when it appeared Trump might win the nomination. The Russian effort was aggressive over the summer months, but seemed to back off and go into cover-up mode following the Access Hollywood revelations and the Obama Administration’s acknowledgement of Russian interference in the fall, realizing they might have gone too far and possibly benefitted Ms. Clinton. However, when Trump won, they changed again and engaged with Ambassador Kislyak in Washington to get in touch with others in the Trump transition team. As this process unfolded, control of operation on the Russian side passed from the Ministry of Foreign Affairs, to the FSB, and later to the Presidential Administration. It should be noted in this context, that the much-reported meetings with Ambassador Kislyak do not seem to be tied to the conspiracy. He is not an intelligence officer, and would be in the position to offer advice on politics, personalities and political culture in the United States, but would not be asked to engage in espionage activity. It is likewise notable that Ambassador Kislyak receives only a passing reference in the Steele dossier and only having to do with his internal advice on the political fallout in the U.S. in reaction to the Russian campaign.

Of course, to determine if collusion occurred as alleged in the dossier, we would have to know if the Trump campaign continued to meet with Russian representatives subsequent to the June meeting. As mentioned, in February, the New York Times, CNN, and Reuters, reported that members of Trump’s campaign and other Trump associates had repeated contacts with senior Russian officials in the year before the election, according to current and former American officials. Subsequent reports cite receipt of intelligence from European security agencies reporting on odd meetings between Trump associates and Russian officials in Europe. And, perhaps the best clue that there might be something to the narrative of meetings in summer 2016 was former CIA Director John Brennan’s carefully chosen phrase in front of the Senate intelligence committee about the contacts – “frequently, people who go along a treasonous path do not know they are on a treasonous path until it is too late.” This period will likely be the one most closely scrutinized by FBI investigators.

In retrospect, there is even some indication that the salacious sexual allegations should not be dismissed out of hand. Efforts to monitor foreigners and develop compromising material is completely consistent with Russian M.O. I am certain that they have terabytes of film and audio from inside my apartment in Moscow. Putin himself is known to have been implicated in several sex stings to embarrass his rivals, to include the famous broadcast of a clandestinely-acquired sex video to shame then Prosecutor General Yuriy Skuratov.

Perhaps more intriguing, the most explosive charge in the Steele document was the claim that Trump hired prostitutes to defile a bed slept in by former President Obama. The important factor to consider is that Trump did not engage with the prostitutes himself, but instead allegedly sought to denigrate Obama. If there is anything consistent in what we have learned about President Trump, it seems that his policies are almost exclusively about overturning and eradicating anything related to President Obama’s tenure. In this sense, he is akin to the ancient Pharaohs, Byzantine and Roman Emperors like Caligula, who sought to obliterate the existence of their predecessors, even destroying and defacing their images. Is it inconceivable that he would get some satisfaction from a private shaming of the former President?

Separate Orbis reports also asserted that Trump himself engaged in unorthodox, perverted sexual behavior over the years that “has provided authorities with enough embarrassing and compromising material on the Republican presidential candidate to be able to blackmail him if they so wished.” While it is not worth serious exploration, the notion that Trump might be involved with beautiful young women as alleged in the reports doesn’t seem to be much of a stretch. His private life is well documented and litigated, such that it doesn’t seem wholly out-of-bounds to tie the reports about his activity in Russia with his history of undue interest in young women. Again, there is no means to independently confirm the information and the media shouldn’t try. An intelligence professional or investigator cannot shy away, however, and should try to ascribe some level of confidence in the information as part of the process of validating the various sources and the overall credibility of the reporting. If the specific reports prove untrue, it would cast doubt on other reporting from that source.

In these cases, blackmail does not need to be overt to be useful. Simple knowledge that a potential adversary might have compromising information can influence behavior. Whether or not his subsequent behavior as a candidate and President is consistent with possible overt or subtle blackmail is beyond my ability to assess or the FBI’s ability to prove, and is instead for each citizen to ponder. Suffice it to say that Trumps obsequiousness toward Putin, his continued cover-ups, and his irrational acquiescence to Russian interests, often in direct opposition to his own Administration and Party, keep the issue on the table.

On the other hand, there is also information in the Steele reports that appears wrong or questionable. For example, the notion that Steele and his team could develop so many quality sources with direct access to discussions inside the Kremlin is worth serious skepticism. The CIA and other professional intelligence services rarely developed this kind of access despite expending significant resources over decades, according to published accounts. It is also hard to believe that Orbis could have four separate sources reporting on the incident at the Moscow hotel. The reputation of the elite hotel in the center of Moscow depends on the discretion of its staff, and crossing the FSB is not something taken lightly in Russian society. A source that could be so easily identified would be putting themselves at significant risk. Further, additional information in the reports cannot be checked without the tools of a professional investigative service. Of course, since the dossier was leaked, and we do not have additional follow-up reports, we don’t know if Orbis would have developed other sources or revised their reporting accordingly as they were able to develop feedback. We also don’t know if the 35 pages leaked by BuzzFeed is the entirety of the dossier. I suspect not.

* * *

So, more than a year after the production of the original raw reports, where do we stand?

I think it is fair to say that the report is not “garbage” as several commentators claimed. The Orbis sources certainly got some things right – details that they could not have known prior. Steele and his company appear serious and credible. Of course, the failure of the Trump team to report details that later leaked out and fit the narrative may make the Steele allegations appear more prescient than they otherwise might. At the same time, the hesitancy to be honest about contacts with Russia is consistent with allegations of a conspiracy.

All that said, one large portion of the dossier is crystal clear, certain, consistent and corroborated. Russia’s goal all along has been to do damage to America and our leadership role in the world. Also, the methods described in the report fit the Russians to a tee. If the remainder of the report is largely true, Russia has a powerful weapon to help achieve its goal. Even if it is largely false, the Kremlin still benefits from the confusion, uncertainty and political churn created by the resulting fallout. In any regard, the Administration could help cauterize the damage by being honest, transparent and assisting those looking into the matter. Sadly, the President has done the opposite, ensuring a Russian win no matter what. In any event, I would suspect the Russians will look to muddy the waters and spread false and misleading information to confuse investigators and public officials.

As things stand, both investigators and voters will have to examine the information in their possession and make sense of it as best they can. Professional investigators can marry the report with human and signals intelligence, they can look at call records, travel records, interview people mentioned in the report, solicit assistance from friendly foreign police and intelligence services, subpoena records and tie it to subsequent events that can shed light on the various details. We, on the other hand, will have to do our best to validate the information at hand. Looking at new information through the framework outlined in the Steele document is not a bad place to start.https://www.justsecurity.org/44697/stee ... r-knowing/

WHAT DOES TRUMP KNOW ABOUT THE RUSSIA DOSSIER? A JUDGE COULD SOON FORCE THE GOVERNMENT TO REVEAL NEW INFORMATIONBY TOM PORTER ON 11/18/17 AT 7:06 AM

A federal court judge is considering whether President Donald Trump's claims about a privately compiled dossier, containing allegations he was ensnared by Russian intelligence, should force the government to reveal more about its attempts to verify the document, Politico reported.

Compiled by former British spy Christopher Steele, the dossier contains a series of lurid claims about the president’s ties to Moscow, most notably that he was recorded cavorting with prostitutes in a Moscow hotel room.

Trump has denounced the dossier in tweets as “fake” and “discredited” —and has called on officials to release information about who funded its research. In an interview with the The New York Times in July, Trump claimed that former FBI director James Comey had briefed him on the dossier.

A federal Judge Friday heard arguments in a Freedom of Information Act lawsuit brought by Politico reporter Josh Gerstein and transparency group the James Madison Project.

Trump’s pronouncements, the plaintiffs argue, mean oblige the government to acknowledge it is is attempting to verify claims in the dossier.

Justice Department lawyer David Glass told U.S. District Judge Amit Mehta that Trump’s claims could be based on other sources, for instance media reports or personal information, and do not necessarily mean he was referring to official investigations.

“There’s no inference that is possible,” Glass said, according to Politico. “It could be based on other things.”

He also argued that Trump’s call for officials to reveal who paid for the dossier does not mean that the FBI and Department of Justice was in possession of that information.

The Steele dossier is currently at the center of a Senate investigation into claims of collusion between the Trump campaign and Russia, with Glenn Simpson, co-founder of the firm that commissioned the document, telling lawmakers Friday that Steele did not pay sources for information contained in it.

MR. BROWN: Joshua Flynn-Brown, InvestigativeCounsel for Senator Grassley. MS. DUCK: Jennifer Duck, Staff Director forSenator Feinstein. MS. QUINT: Lara Quint, Chief Counsel,Senator Whitehouse. MS. SAWYER: Heather Sawyer, Chief OversightCounsel, Senator Feinstein. MS. CLAFLIN: Molly Claflin, Counsel, SenatorFeinstein. MR. DAVIS: The Federal Rules of CivilProcedure do not apply to any of the committee'sinvestigative activities, including transcribedinterviews. There are some guidelines we follow,and I'll go over those now. Our questioning will proceed in rounds. Themajority staff will ask questions first for onehour, then the minority staff will have anopportunity to ask questions for an equal amount oftime. We will go back and forth until there are nomore questions and the interview is over. We typically take a short break at the end ofeach hour, but should you need a break at any othertime, please just let us know. And we can discusstaking a break for lunch whenever you're ready toPage 6￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

doso.We have an official reporter taking downeverything we say to make a written record. So weask that you give verbal responses to allquestions. Do you understand? MR. SIMPSON: Yes. MR. DAVIS: So that the court reporter cantake down a clear record, we'll do our best tolimit the number of people directing questions atyou during any given hour to those whose turn itis. It's also important that we don't talk overone another or interrupt each other to the extentwe can help it. That goes for everybody present attoday's interview. We encourage witnesses who appear before thecommittee to freely consult with counsel if theyshould choose. You are appearing here today withcounsel. Counsel, could you please state your namefor the record. MR. LEVY: Josh levy. MR. MUSE: I'm Bob Muse and I represent GlennSimpson. MS. CLATTENBURG: I'm Rachel Clattenburg. MR. DAVIS: We want you to answer ourquestions in the most complete and truthful mannerPage 7￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 possible. So we will take our time. If you have 2 any questions or if you don't understand any of our 3 questions, please let us know. If you honestly 4 don't know the answer to a question or don't 5 remember, it's best not to guess. Just give us 6 your best recollection. 7 It's okay to tell us if you learned 8 information from somewhere else if you indicate how 9 you came to know the information. If there are10 things that you don't know or can't remember, we11 ask that you inform us to the best of your12 knowledge who might be able to provide a more13 complete answer to the question.14 This interview is unclassified. So if any15 question calls for information that you know to be16 classified, please state that for the record as17 well as the reason for the classification. Then18 once you've clarified that to the extent possible,19 please respond with as much unclassified20 information as you can. If we need to have a21 classified session later, that can be arranged.22 It is this committee's practice to honor23 valid common law privilege claims as an24 accommodation to a witness or party when those25 claims are made in good faith and accompanied byPage 8￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 sufficient explanation so that the committee can 2 evaluate the claim. When deciding whether to honor 3 a privilege the committee weighs its need for the 4 information against any legitimate basis for 5 withholding it. The committee typically does not 6 honor contractual confidentiality agreements. 7 The committee and Mr. Simpson have agreed 8 that this interview is occurring without prejudice 9 to any future discussions with the committee and we10 reserve the right to request Mr. Simpson's11 participation in future interviews or to compel his12 testimony. The committee and Mr. Simpson have also13 agreed that participation in this interview does14 not constitute a waiver of his ability to assert15 any privileges in response to future appearances16 before this committee.17 Mr. Simpson, you should understand that18 although the interview is not under oath, by law19 you are required to answer questions from Congress20 truthfully. Do you understand that?21 MR. SIMPSON: Yes.22 MR. DAVIS: Specifically 18 U.S.C. Section23 1001 makes it a crime to make any materially false,24 fictitious, or fraudulent statement or25 representation in the course of a congressionalPage 9￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼investigation. That statute applies to yourstatements in this interview. Do you understandthat? MR. SIMPSON: Yes, I do. MR. DAVIS: Witnesses who knowingly providefalse statements could be subject to criminalprosecution and imprisonment for up to five years.Do you understand this? MR. SIMPSON: Yes, I do. MR. DAVIS: Is there any reason you're unableto provide truthful answers to today's questions? MR. SIMPSON: No. MR. DAVIS: Finally, we ask that you notspeak about what we discuss in this interview withanyone else outside of who's here in the room todayin order to preserve the integrity of ourinvestigation. We also ask that you not remove anyexhibits or other committee documents from theinterview. Once again, the Chairman and Ranking Memberwithdrew their subpoena of you due to yourwillingness to provide information in thisvoluntary interview and document production.However, the extent to which the committee deemsfurther compulsory process necessary will likelyPage 10￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

depend on your level of cooperation and candor. Is there anything else that my colleaguesfrom the minority would like to add? MS. SAWYER: Thank you. We appreciate it.And we appreciate you being here as part of theinvestigation into the Russian interference intothe 2016 election. I did want to, with agreement of mycolleagues, just enter into the record the letteragreement regarding the interview that was sent toyour counsel on August 3, 2017. I think mycolleague has gone over a number of the parametersthat we agreed to, but I think it would be helpfulto have this in the record. So we'll go ahead andmark it as Interview Exhibit No. 1 just foridentification purposes. (Interview Exhibit 1 was marked for identification.) MS. SAWYER: With that, again, thank you forbeing here. MR. DAVIS: The time is now 9:40 and we willget started with the first hour of questions.EXAMINATIONBY MR. DAVIS: Q. Mr. Simpson, what is your professionalPage 11￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

background? A. I have a degree in journalism from GeorgeWashington University and I've spent most of myworking adult life as a journalist, much of it asan investigative reporter for the Wall StreetJournal. Prior to that I worked as aninvestigative reporter at Roll Call Newspaperwriting about political corruption, financialcrime, terrorism, tax evasion, stock fraud,financial scandals, congressional investigations,government prosecutions, money laundering,organized crime. Q. And when did you leave the Wall StreetJournal?A. In 2009. Q. And did you found SNS Global after leavingthe Wall Street Journal? A. That's right. Q. And how many employees and associates didSNS Global have? A. There were two partners and in the firstpart of the time I think we had one employee. No,I'm sorry. We had two employees. Q. And who were they? A. We had a research assistant named MargotPage 12￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Williams, M-A-R-G-O-T Williams, and anotheradministrative assistant whose name I don't recallright now. Q. And who was the other partner? A. Susan Schmidt was my other partner, formercolleague from the Wall Street Journal, and priorto that was an investigative reporter at theWashington Post. Q. And what was the nature of SNS Global'sbusiness? A. Research, business intelligence. Q. And what types of clients did SNS Globalhave? A. It's a while ago, so it's not fresh in mymind. Other consulting firms, lawyers. I don'tspecifically remember a lot of them. Q. And is SNS Global still in business? A. No. Q. When did it cease operations? A. I believe at the end of 2010. Q. And why did it -- why did SNS Global ceaseoperations? A. Basically my partner and I had differentambitions for what we wanted to do. I wanted tohave a brick and mortar office with more resourcesPage 13￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 and staff. Basically I concluded that the work 2 that we were doing required more infrastructure and 3 resources. Basically in modern research you need 4 to have access to a lot of different databases and 5 there's a lot of aspects of the work that are 6 administrative in nature that require things that I 7 wasn't able to do. I prefer to spend my time doing 8 the research. So I wanted to have more of an 9 infrastructure where I could focus on that.10 Q. What is Bean, LLC?11 A. That's the LLC that is my current12 company.13 Q. And what is your role in Bean, LLC?14 A. I'm the majority owner. I guess, you15 know, we don't have official titles, but I'm16 generally referred to as the CEO.17 Q. Bean, LLC registered Fusion GPS as a trade18 name in the District of Columbia; is that correct?19 A. Yes, it's a DBA.20 Q. Why did you choose to use a trade name for21 Bean, LLC rather than directly name the company22 Fusion GPS?23 A. Because at the time that I was deciding24 what I wanted to do I was recruiting a new partner25 and I just needed to set up a holding company whilePage 14￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

I organized my new business. So I just picked aname. You know, a bean is a seed, a new thing. SoI picked that name to begin the process oforganizing a new business and didn't want to selectan actual DBA, you know, a brand name until Iconsulted with my new partner. We wanted tomutually -- I actually had two partners in thebeginning, so there were three of us, and I wantedto make it a group decision. Q. Is Bean, LLC currently registered in D.C.to conduct business under the trade name FusionGPS? A. To my knowledge it is. It should be. Q. Have any other LLC's or business entitiesconducted business as Fusion GPS? A. I don't think so. Q. Have any other LLC's or business entitiesreceived payments for work conducted by Fusion GPS,its employees, or its associates? MR. LEVY: Are you asking to includesubcontractors or are you -- MR. DAVIS: Sure. MR. LEVY: Does Fusion GPS havesubcontractors? MR. DAVIS: Right. I think that would bePage 15￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

part of it, but the other part is: are there otherLLC's associated with Bean direct- -- with Bean orFusion directly, not just subcontractors?BY THE WITNESS: A. Yes. I mean, the one I think that hascome up in some of the correspondence or somewhere,I can't remember where, is another one calledKernel, K-E-R-N-E-L, and that was an LLC that wasset up for a book project that never -- we neverfinished -- we never did the book. So it'sinactive with the current time. Then there'sanother one that one of my partners manages that'sfor different types of work, technology, policy,and that type of thing. Q. What's the name of that one? A. I think it's Caudex, C-A-U-D-E-X. Q. And are any other LLC's or types ofbusiness entities otherwise associated with FusionGPS? A. Those are the only ones I can think of. Q. And have you been a registered agent,owner, or beneficial owner of any other LLC's orbusiness entities? A. I own an LLC in Maryland that holds someproperty that I own.Page 16￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ Q. And what's the name of that LLC? A. As we sit here, I wasn't prepared for thisquestion, I don't remember the name of it. It wasregistered fairly recently. Obviously we can getthat to you. Q. So is it correct that Fusion has at timesworked with different LLC's based on by project? A. For most of the history of the companyBean, LLC was the primary entity through which wedid business. I'm not sure I totally understandyour question. There's this other LLC I mentionedthat's fairly recent and there may be otherentities, but nothing that I, myself set up, atleast not that I can think of. Q. Anything that your partners would have setup? A. Not that I can think of. Q. Does Fusion GPS, Bean, LLC, Kernel, LLC,or any of these other related business entitieshave any bank accounts outside of the UnitedStates?A. No.Q. Domestically does Bean, LLC have an account at ￼ ?A. Yes.Page 17￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MR. LEVY: I don't know that we need to getinto bank accounts. MR. DAVIS: Are you offering a basis for thatobjection? MR. LEVY: It's outside the scope of theinterview. MR. DAVIS: Part of the questions we've askedare actions Fusion has taken -- interactions Fusionhas had and we're trying to define the scope ofwhat Fusion is as a predicate to understandingthose answers. MR. LEVY: Yeah, and he's answering thosequestions. MR. FOSTER: He answered yes to the question.BY MR. DAVIS: Q. Where is Fusion GPS's physical office, ifany? A. DuPont Circle. Q. Is it, if I recall correctly, 1700Connecticut Avenue, Northwest? A. That's the address, yes. Q. Is it Suite 400? A. It is. Q. How many employees and associates doesFusion GPS currently have?Page 18￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court Reporting￼Glenn SimpsonAugust 22, 2017Washington, DC

Q. In general, what is Fusion GPS's business? A. We primarily are a research, strategy,consulting firm. Q. And what types of clients has Fusion GPShad? A. It runs the gamut from corporations to lawfirms, various investment funds, people involved inlitigation. Q. And roughly how many active clients -- MR. LEVY: Did you finish? I don't know ifhe finished. MR. DAVIS: I'm sorry.BY THE WITNESS: A. It's hard to categorize them all. Thoseare some of the main types of clients we have. Q. And roughly how many active clients didFusion GPS have in 2016? A. That's difficult for me to answer. Youknow, over ten I would say, but it's hard for me --beyond that I would be guessing. Q. Does part of Fusion GPS's business involveattempting to have media outlets publish articlesthat further the interests of your clients? A. Yeah, you could -- I mean, generallyspeaking, we are -- generally we tend to respond toPage 20￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

inquiries more than try to push things, but, youknow, we work with the press frequently. Q. And has Fusion GPS ever providedinformation to journalists in order to encouragethem to publish articles or air stories thatfurther your client's interests?A. Yes. Q. And has Fusion GPS provided information tojournalists or editors in order to discourage themfrom publishing or airing stories that are contraryto your client's interests? A. Well, what we -- we're a research company.So generally what we do is provide people withfactual information. Our specialty is publicrecord information. So if we get an inquiry abouta story and some of the information that areporter's presuming is incorrect and we give themcorrect information, that may cause them to notwrite the story. Q. Has Fusion GPS ever had arrangements withclients in which the amount of Fusion'scompensation was dependent on getting articlespublished or stories aired? A. Not that I can recall. Q. Has Fusion GPS ever had arrangements withPage 21￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

clients in which the amount of Fusion'scompensation was dependent upon preventing articlesfrom being published or stories from being aired? A. No, I don't think so, not to myrecollection. Q. To the best of your knowledge, has anyoneassociated with Fusion GPS ever told clients orprospective clients that the company could find anddistribute information or take other actions inorder to encourage government agencies to initiatean investigation? A. Could you restate that? Q. To the best of your knowledge, has anyoneassociated with Fusion GPS ever told clients orprospective clients that the company could find anddistribute information or take other actions inorder to encourage government agencies to initiatean investigation? MR. LEVY: Within the scope of thisinterview? MR. DAVIS: In general. I'm not asking aboutany particular case. MR. LEVY: Hold on. Let's -- let me justtalk to my client about that and get back to you onthat. I just want to understand the facts so wePage 22￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

can evaluate whether it's appropriate to discussthat here if such a predicate for the answerexists. MR. FOSTER: Do you want to take a break? MR. LEVY: Sure. MR. FOSTER: Let's go off the record. It's9:55.It's 10:02.BY MR. DAVIS: Q. After conferring with your counsel, areyou able to answer the question? A. Yes. Could you just state it one moretime. Q. Sure. To the best of your knowledge, hasanyone associated with Fusion GPS ever told clientsor prospective clients that the company could findand distribute information or take other actions inorder to encourage government agencies to initiatean investigation? A. The word "associated" is really vague.I'm not sure I know what you mean by that. I canspeak to my own practices and the practices of thepeople who work at my company. (A short break was had.)MR. DAVIS: We'll go back on the record.Page 23￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 Generally speaking, when we do a research 2 project for a new client and they ask us -- you 3 know, they explain, you know, what situation 4 they're involved in, if it's a lawsuit, for 5 example, or some other dispute, a lot of what we do 6 is related to disputes, they say -- you know, we 7 say we will conduct an open-ended inquiry that's 8 not goal directed and the results of the research 9 will guide whatever decision you want to make about10 how to use it.11 So the range of possibilities with, you know,12 research are you could file a lawsuit, you could13 put it in a court filing, you could take it to a14 government agency, you could give it to Congress,15 you could give it to the press, but you don't16 really prejudge, you know, how you're going to use17 information until you know what you've got.18 So we generally don't let our clients dictate19 sort of the -- you know, the end result of things20 because we don't think that's an intelligent way of21 trying to do research and, you know, a lot of what22 we do is decision support. Your clients are23 frequently trying to make a decision about how they24 want to proceed, whether they want to -- you know,25 if someone thinks they've been defrauded, you canPage 24￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 file a lawsuit, you can go to the police. You 2 would decide that based on what you find out about 3 the, you know, evidence of a fraud. So that's 4 generally the way we do it. 5 Q. To the best of your knowledge, has Fusion 6 GPS ever had an arrangement with a client in which 7 the company was specifically tasked with getting 8 government agencies to initiate an investigation? 9 A. I would -- to the best of my recollection,10 we don't have any agreements like that we would put11 into writing generally for the reasons I stated in12 answer to the previous question. In the course of,13 you know, dealing with a client we might talk about14 whether, you know, something was worthy of a15 government investigation and talk about how that16 could be done. There's any number of scenarios17 there that might come under discussion, but, as I18 say, that's generally not how we frame a project.19 Q. Has Fusion GPS ever had arrangements with20 clients in which the amount of Fusion's21 compensation was dependent on government agencies22 initiating an investigation?23 A. We've been in business since 2010, so24 seven years is a fairly long time, but as I say,25 not to my recollection. I just can't bePage 25￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 categorical because we've done a lot of work over 2 the last seven years. 3 Q. So I'm going to move on now to some 4 questions about Prevezon Holdings and the Magnitsky 5 Act. I want to sort of generally make it clear 6 when I refer to you or to Fusion, I mean not just 7 you personally, but all employees and associates of 8 Fusion GPS and its component LLC's and legal 9 entities as well as any contractors or10 subcontractors. If it's not clear to you who I'm11 referring to in the question, please just ask and12 I'll clarify.13 Similarly, I'm going to refer to Prevezon and14 Magnitsky, M-A-G-N-I-T-S-K-Y. When I refer to15 those together, I mean all matters related to the16 Justice Department's lawsuit against Prevezon17 Holdings Limited, as well as all matters related to18 efforts with the media, government officials, and19 campaigns to overturn the Magnitsky Act, prevent20 the passage of the global Magnitsky Act, remove the21 word Magnitsky from either law, the Russian ban on22 U.S. adoptions of Russian children, research on Mr.23 Magnitsky himself or Mr. Browder, Hermitage Capital24 Management and its affiliated companies. So I'm25 generally putting those under that umbrella. IfPage 26￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

you need me to clarify for any specific question,just ask. MR. LEVY: You obviously said a lot there. MR. DAVIS: I did. MR. LEVY: And so on a question-by-questionbasis out of fairness to the witness, I just wantto make sure that he has the ability to askclarification, of course, as questions arise. MR. DAVIS: Right. That's what I would beasking you to do. MR. LEVY: Even now, quite frankly, I'm notsure I can recall everything that you baked intothe term that you're going to use. MR. DAVIS: Feel free to raise questionsabout any particular question we ask. MR. LEVY: Okay.BY MR. DAVIS: Q. Mr. Simpson, what was Fusion GPS's role inthe Justice Departments's litigation againstPrevezon Holdings? A. We were retained by Baker Hostetler in thespring of 2014 to do litigation support, and underthe heading of litigation support was thingsrelated to discovery, locating witnesses, answerquestions from the press, gathering documents,Page 27￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

pretty much, you know, a conventional understandingof litigation support. Q. And to whom did Fusion GPS report in thecourse of this work? A. Baker Hostetler. The partner in chargewas Mark Cymrot, C-Y-M-R-O-T, who's a partner inthe Washington office and former Justice Departmentprosecutor. Q. Did Mr. Cymrot provide instructions toFusion GPS during the course of the work? A. Mr. Cymrot regularly instructed us in howwe were to go about doing discovery and variousother tasks, yes. Q. And for a portion of that case at leastMr. Cymrot was the attorney of record for PrevezonHoldings; is that correct? A. For the entirety of the time that I workedon the case he was -- I believe he was the attorneyof record. Q. And did you understand the instructionsyou received from him to be originating from hisclient, from Prevezon Holdings? A. The ultimate direction, of course, wouldhave been from the ultimate client, but the clientwas outside the United States for most of its time.Page 28￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 So, you know, a lot of instruction came from him 2 and he was the person who formulated the legal 3 strategy, undertook all of the legal efforts to 4 work the case. 5 Q. And when did Fusion GPS cease working on 6 the Prevezon Holdings case? 7 A. I can't say exactly. It was mid to late8 2016. 9 Q. Which of Fusion's associates and employees10 have worked on the Prevezon or Magnitsky issues?11 A. For the most part it was myself and one of12 my analysts, ￼ . There may have -- from13 time to time issues may have come up about trying14 to find records or other issues where I conferred15 with or enlisted someone else in the office, but I16 don't specifically recall.17 MR. FOSTER: To follow up on the previous18 answer, you said mid to late 2016 is when the19 investigation ended, generally speaking. Do you20 have any records that could refresh your21 recollection about the exact date at a later time?22 MR. SIMPSON: I'm sure we do, yes. I am --23 we have a division of labor and I don't do a lot of24 things like invoicing. So this is not going to be25 my strong suit.Page 29￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MR. FOSTER: But you could figure it outlater for us? MR. SIMPSON: We maintain books and records. MR. FOSTER: Could you maybe just describequickly what kind of record would constitute theend of the engagement? MR. SIMPSON: That's a good question. Youknow, in some cases there's no specific terminationletter. So I don't know whether there's atermination agreement or termination letter in thiscase. I mean, generally speaking, you know, whenwe stop billing the case is over. (Exhibit 2 was marked for identification.)BY MR. DAVIS: Q. I'd like to introduce an exhibit. It'sone of two privilege logs that your attorneysprovided us. This will be Exhibit 2. Mr. Simpson, on the third page of thisdocument, the last two entries appear to be e-mailssent on October 27, 2016 from Peter Fritsch to MarkCymrot CC'g you. To the best of your recollection,was Fusion GPS still working for Mr. Cymrot on --still working for Baker Hostetler on the Prevezoncase as of the date of this e-mail?Page 30￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

A. I don't know. Q. The privilege asserted was attorney workproduct. Do you know what the basis of that was? A. Well, it was a legal -- MR. LEVY: This is a judgment that hislawyers made and any knowledge he would have aboutwhether it was attorney work product or not likelywould come from communications with counsel, whichobviously are privileged.BY MR. DAVIS: Q. Did Fusion ever work with subcontractorson its Prevezon or Magnitsky efforts? A. Yes. Q. Who were they? MR. LEVY: Just to clarify that, yourquestion was -- can you repeat the question,please? MR. DAVIS: Sure. Did Fusion ever work withsubcontractors on its Prevezon or Magnitskyefforts? MR. LEVY: What do you mean by "Magnitskyefforts"? MR. DAVIS: I mean all matters related to theefforts with the media, government officials, andcampaigns -- or campaigns to overturn the MagnitskyPage 31￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 Act, prevent the passage of the global Magnitsky 2 Act, remove the word Magnitsky from the law -- from 3 either law, as well as the Russian ban on U.S. 4 adoptions of Russian children. 5 MR. LEVY: And you were also asking about 6 subcontractors for Prevezon as well? 7 MR. DAVIS: I'm asking whether Fusion ever 8 worked with subcontractors on those issues. 9 BY THE WITNESS:10 A. Well, I object to the question the way the11 question is framed. You've sort of built into the12 question the sort of inference that we were doing13 something other than working on a legal case, and14 there's extensive public record, documentation in15 Pacer of the work that we did and it was a legal16 case. So I don't -- it's going to be difficult17 because it's really hard for me to answer questions18 where you lump in all these things that other19 people were doing and impute them to me.20 Q. Let's break them down by category.21 A. Let's do that.22 Q. Did Fusion ever work with23 subcontractors -- did Fusion ever hire24 subcontractors as part of its legal work on the25 Prevezon case?Page 32￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ A. Yes. Q. And whom did you hire? A. I think the primary, possibly only one wasa guy named Edward Baumgartner. There may havebeen others. I just don't recall. Q. And what type of work did Mr. Baumgartnerundertake for Fusion? A. Discovery mostly, helping locatewitnesses. He speaks Russian. So he would workwith the lawyers on gathering Russian languagedocuments, gathering Russian language mediareports, talking to witnesses who speak Russian,that sort of thing. He may have dealt with thepress. I just don't remember. MR. FOSTER: What is his professionalbackground? MR. SIMPSON: He has a degree in Russian. MR. FOSTER: So his primary role was as aRussian speaker? Is he a private investigator?What does he do? MR. SIMPSON: He runs a consulting firm likeme and deals with issues more in Ukraine thanRussia, but in both. Yeah, he was doing Russianlanguage things. The case revolved around,centered on events in Russia. So a lot of what wePage 33￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

don't speak Russian, I've never been to Russia. Soit would be ordinary course of business for me toidentify a specialist who could supply me with thatkind of specialized expertise.BY MR. DAVIS: Q. And how did you come to hire him for thisengagement? A. I met him on a previous engagement and Iwas impressed by his knowledge of the region andhis general abilities. MR. FOSTER: What was the previousengagement? MR. LEVY: We're not going to get into priorengagements. It's outside the scope. MR. FOSTER: Generally speaking, what was it? MR. SIMPSON: It was something involvingRussia. MR. FOSTER: A little more specificallyspeaking. MR. SIMPSON: It's my understanding that Iwas not required to talk about my other cases atthis interview. MR. DAVIS: Again, it's a voluntary interview1 needed to find out were things that were in Russia2 or there were documents in the Russian language. IPage 34￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 and you are not under compulsion to answer any 2 questions, but, again, the extent to which you 3 cooperate will help the committee members evaluate 4 whether further compulsory process is necessary. 5 MR. LEVY: He's been answering questions and 6 we're here all day for you. 7 MR. SIMPSON: I'm here to cooperate. 8 BY MR. DAVIS: 9 Q. Did anyone from Fusion ever work with10 other subcontractors hired by Baker Hostetler for11 the Prevezon case?12 A. That would have been ordinary. I don't13 specifically remember doing that, but it wouldn't14 have been out of the ordinary. It's not15 particularly noteworthy. I've worked with Baker16 Hostetler since 2009 on a number of legal cases.17 This is the only one that involved Russia. And in18 the course of any legal case, you know, various19 people are retained by a law firm to perform20 various services. So you would meet other21 subcontractors in the course of doing legal work.22 That's common.23 Q. What types of services would they tend to24 be providing?25 A. Translators would be common, in this casePage 35￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 particularly. Forensic people, accountants, PR 2 people, all those services are facets of modern 3 litigation. 4 Q. And to the best of your knowledge, did 5 Fusion ever work with any other contractors hired 6 by Prevezon Holdings? 7 A. I'm sorry. Could you repeat that? 8 Q. Sure. I asked if Fusion had hired any 9 subcontractors that you worked with on the Prevezon10 matter, whether Baker hired anyone that you worked11 with. Now I'm wondering did you work with anyone12 hired directly through Prevezon on this as opposed13 to Baker Hostetler?14 A. It's difficult to give a yes or no answer15 to that. I would have to say I think so, but when16 you're a subcontractor to a law firm, you know,17 you're sort of in a lane and, you know, my lane was18 research, discovery, William Browder's business19 practices, his activities in Russia, his history of20 avoiding taxes.21 So people -- other people, you know, in a big22 case come and go and it's not really my position to23 ask, you know, who hired them and why. Generally24 if I'm introduced to somebody they'll explain, you25 know, why there were other lawyers who worked forPage 36￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 Prevezon who were part of the case. Other people 2 were brought in -- you know, were brought in either 3 by Prevezon or by the lawyers and I didn't always 4 try to pin that down. 5 Q. In general would the decision whether you 6 would share Fusion's information with them be 7 dependent then upon the attorneys introducing you8 to them? 9 A. It would be dependent on the direction of10 the attorneys. I basically -- you know, in all11 these cases for reasons of privilege and simply12 just professionalism you work at the direction of13 the lawyers and you do what they instruct you to14 do.15 Q. Did anyone from Fusion ever help arrange16 for other entities to be hired by Prevezon or Baker17 Hostetler for the Prevezon case?18 A. I don't think you could say we arranged19 for others to be hired. If you're asking me if we20 made referrals, we would refer -- you know, we made21 quite extensive -- fairly extensive efforts to get22 a PR firm hired for the trial that we were23 expecting and we made a number of referrals in that24 case, in that matter.25 Q. What was the name of that PR firm?Page 37￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 A. There were several. We actually, you 2 know, had a series of screening sessions. I think 3 Weber Shandwick was the one we ended up with. 4 Q. You mentioned that Fusion was conducting 5 litigation support in regard to the Prevezon case. 6 Could you expand a little more about what type of 7 litigation support activities you undertook? 8 MR. LEVY: Beyond what he's already told you? 9 MR. DAVIS: With a little more detail.10 BY THE WITNESS:11 A. Yes. In the original period of the case12 the question -- the client's explanation for or13 response to the government's allegations was that14 they originated with an organized crime figure in15 Russia who had been extorting them and who they had16 reported to the police and who had been jailed and17 convicted for blackmailing them, and they claimed18 that that was where these allegations originated,19 which, you know, seemed remarkable because it was20 in a Justice Department complaint.21 So the first thing, you know, in any case22 really is to sort of try and figure out whether23 your own client's story can be supported or whether24 it's not true, and the lawyers -- you know, we work25 with a lot of prominent law firms and in many casesPage 38￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 39 1 the first thing the lawyers need to know is whether 2 their client's story is real, whether it can be 3 supported, you know, because in any new case you 4 don't know whether your own client is telling you5 the truth. 6 So originally one of the first things we were 7 hired to do was to check out whether this was, in 8 fact, the case. So they claimed that the 9 allegations originated with a mobster named Demetri10 Baranovsky, B-A-R-A-N-O-V-S-K-Y, who was, in fact,11 jailed for running a shake-down operation in which12 he posed as an anticorruption campaigner for the13 purpose of extorting money from people by14 threatening to accuse them of some kind of corrupt15 activities. As you know, Russia is rife with16 corruption and there's a lot of anger over17 corruption.18 We were able to ascertain that Mr. Baranovsky19 was, in fact, associated with Russia's biggest20 organized crime family, the Solntsevo Brotherhood,21 S-O-L-N-T-S-E-V-O brotherhood, which is the major22 dominant mafia clan in Moscow. So as far as it23 went, the client seemed to be telling the truth.24 You know, there was extensive record of these25 events and we found some indications from western￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 law enforcement that western law enforcement did 2 consider Baranovsky to be a lieutenant in this 3 organized crime family. So we did that for a 4 while. Edward Baumgartner helped a lot with that 5 because of his Russian language skills and his 6 ability to interface with the court system in7 Russia. 8 And, you know, around the -- similarly, there 9 was a deposition of a customs agent by one of the10 lawyers who -- you know, in this initial effort to11 trace the origin of these allegations, where they12 came from, how they could have ended up with the13 Justice Department, the first thing we did was14 interview the client, got their story, and15 interviewed the agent who worked on the case for16 the DOJ and that agent said he got all his17 information from William Browder.18 So at that point I was asked to help see if19 we could get an interview with William Browder.20 They wrote a letter to Browder and asked him to21 answer questions and he refused. Then the lawyers22 wanted to know, you know, whether he could be23 subpoenaed. So a lot of what I did in 2014 was24 help them figure out whether he could be subpoenaed25 in the United States to give a deposition, and thePage 40￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 first thing that we did was we researched the 2 ownership and registration of his hedge fund, which 3 was registered in Delaware and filed documents with 4 the Securities and Exchange Commission. 5 So we subpoenaed his hedge fund. A lot of 6 the early work I did was just documenting that his 7 hedge fund had presence in the United States. So 8 we subpoenaed his hedge fund. He then changed the 9 hedge fund registration, took his name off, said it10 was on there by accident, it was a mistake, and11 said that he had no presence in the United States12 and that, you know -- as you may know, he13 surrendered his citizenship in 1998 and moved14 outside the United States. That was around the15 time he started making all the money in Russia. So16 he's never had to pay U.S. taxes on his profits17 from his time in Russia, which became important in18 the case later.19 In any case, he said he never came to the20 United States, didn't own any property here, didn't21 do any business here, and therefore he was not22 required to participate in the U.S. court system23 even though he admitted that he brought the case to24 the U.S. Justice Department. So we found this to25 be a frustrating and somewhat curious situation.Page 41￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 He was willing to, you know, hand stuff off to the 2 DOJ anonymously in the beginning and cause them to 3 launch a court case against somebody, but he wasn't 4 interesting in speaking under oath about, you know, 5 why he did that, his own activities in Russia. 6 So looking at the public record we determined 7 that he did come to the United States frequently, 8 and I discovered through public records that he 9 seemed to own a house in Aspen, Colorado, a very10 expensive mansion, over $10 million, which he had11 registered in the name of a shell company in a12 clear attempt to disguise the ownership of the13 property. We were able to ascertain that he does14 use that property because he registered cars to15 that property with the Colorado DMV in the name of16 William Browder.17 So we began looking for public information18 about when he might be in Aspen, Colorado, and I19 found a listing on the Aspen Institute Website20 about an appearance he was going to make there in21 the summer of 2014. So we -- I served him a22 subpoena in the parking lot of the Aspen Institute23 in the summer of 2014 using two people -- two24 subcontractors. Actually, those other25 subcontractors were -- their names escape me, but IPage 42￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 forgot about those. We can get you that. This is 2 all in the Pacer court record, the public court3 record. 4 In any event, the three of us served -- there 5 was another subcontractor working for the law firm 6 whose name I also forget. I did not retain him, 7 but I was asked to work with him on this. He is a 8 private investigator and we can get you his name. 9 In any event, we served him the subpoena and he ran10 away. He dropped it on the ground and he ran away.11 He jumped in his car and went back to his mansion.12 At that point he tried to suppress -- tried13 to quash the subpoena on the grounds it hadn't been14 properly served. We didn't get a video, but there15 are sworn affidavits from my servers in the court16 record about the service. But he objected to it on17 a number of grounds. A, he continued to insist he18 had nothing to do with the United States and didn't19 come here very often even, though we caught him20 here, clearly has cars in Colorado. He also said21 that you can't serve a subpoena for a case in22 New York in the state of Colorado, it's outside the23 primary jurisdiction. He also began to raise24 questions about whether Baker Hostetler had a25 conflict of interest because of some previous workPage 43￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 he did with one of the Baker lawyers. 2 This led to a long, drawn-out discovery 3 battle that I was in the center of because I served 4 the subpoenas and I helped find the information for 5 the first set of subpoenas that lasted, you know, 6 through 2014. This was, you know, a lot of what I 7 did. This was -- the main focus was on trying to 8 get William Browder to testify under oath about his 9 role in this case and his activities in Russia.10 All of this -- his determined effort to avoid11 testifying under oath, including running away from12 subpoenas and changing -- frequently changing13 lawyers and making lurid allegations against us,14 including that, you know, he thought we were KGB15 assassins in the parking lot of Aspen, Colorado16 when we served the subpoena, all raised questions17 in my mind about why he was so determined to not18 have to answer questions under oath about things19 that happened in Russia.20 I'll add that, you know, I've done a lot of21 Russia reporting over the years. I originally met22 William Browder back when I was a journalist at the23 Wall Street Journal when I was doing stories about24 corruption in Russia. I think the first time I met25 him he lectured me about -- I was working on aPage 44￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 story about Vladimir Putin corruption and he 2 lectured me about how have Vladimir Putin was not 3 corrupt and how he was the best thing that ever 4 happened to Russia. There are numerous documents 5 that he published himself, interviews he gave 6 singing the praises of Vladimir Putin. At that 7 time I was already investigating corruption in 8 Putin's Russia. 9 So this made me more curious about the10 history of his activities in Russia and what that11 might tell me about corruption in Russia, and as12 part of the case we became curious about whether13 there was something that he was hiding about his14 activities in Russia. So through this period while15 we were attempting to get him under oath we were16 also investigating his business practices in Russia17 and that research -- and I should add when I say18 "we," I mean the lawyers were doing a lot of this19 work and it wasn't -- I can't take responsibility20 or pride of place on having done all this work. We21 were doing it all together. It was a -- you know,22 there were a number of lawyers involved, other23 people.24 In the course of doing this research into25 what he might not want to be asked about from hisPage 45￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 history in Russia we began to learn about the 2 history of his tax avoidance in Russia and we began 3 to deconstruct the way that his hedge fund 4 structured its investments in Russia and, you know, 5 we gradually accumulated through public records, 6 not all from Russia, that he set up dozens of shell 7 companies in Cyprus and other tax havens around the 8 world to funnel money into Russia and to hold 9 Russian securities.10 He also set up shell companies inside of11 Russia in order to avoid paying taxes in Russia and12 he set up shell companies in a remote republic13 called Kalmykia, K-A-L-M-Y-K-I-A, which is next to14 Mongolia. It's the only Buddhist republic in15 Russia and there's nothing much there, but if you16 put your companies there you can lower your taxes.17 They were putting their companies in Kalmykia that18 were holding investments from western investors and19 they were staffing these companies -- they were20 using Afghan war veterans because there's a tax21 preference for Afghan war veterans, and what we22 learned is that they got in trouble for this23 eventually because one of Putin's primary rules for24 business was you can do a lot of things, but you've25 got to pay your taxes.Page 46￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 In fact, William Browder famously said in 2 2005 at Davos everybody knows under Putin you have 3 to pay your taxes, which is ironic because at the 4 time he was being investigated for not paying 5 taxes. Ultimately they were caught, some of these 6 companies were prosecuted, and he was forced to 7 make an enormous tax payment to the government of 8 Russia in 2006. 9 I will add that Sergei Magnitsky was working10 for him at this time and all of this happened prior11 to the events that you are interested in involving12 the Russian treasury fraud and his jailing. This13 precedes all that.14 But returning to the detailed discussion of15 my work, we investigated William Browder's business16 practices in Russia, we began to understand maybe17 what it was he didn't want to talk about, and as we18 looked at that we then began to look at his19 decision to surrender his American citizenship in20 1998. At that point somewhere in there the Panama21 papers came out and we discovered that he had22 incorporated shell companies offshore in the mid23 1990s, in 1995 I believe it was in the British24 Virgin Islands, and that at some point his hedge25 fund's shares had been transferred to this offshorePage 47￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 company. 2 This offshore company was managed -- several 3 of his offshore companies were managed by the 4 Panamanian law firm called Mossack Fonseca, 5 M-O-S-S-A-C-K, Fonseca, F-O-N-S-E-C-A, which is 6 known now for setting up offshore companies for 7 drug kingpins, narcos, kleptos, you name it. They 8 were servicing every bad guy around. And I'm 9 familiar with them from other money laundering and10 corruption and tax evasion investigations that I've11 done.12 I'll note parenthetically that William13 Browder talks a lot about the Panama papers and the14 Russians who are in the Panama papers without ever15 mentioning that he's in the Panama papers. This16 is, again, a public fact that you can check17 on-line.18 So that's an overview of the sort of work I19 was doing on this case. In the course of that I20 also began reaching back, I read his book Red21 Notice to understand his story and the story of his22 activities in Russia. I'll add also that I was23 extremely sympathetic for what happened to Sergei24 Magnitsky and I told him that myself and I tried to25 help him. It was only later from this other casePage 48￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 that I began to be curious and skeptical about 2 William Browder's activities and history in Russia. 3 MR. FOSTER: Can I ask you a follow-up 4 question. I appreciate the narrative answer, but 5 at the very beginning of the narrative you talked 6 about beginning this journey by interviewing -- 7 conducting an interview of the case agent who said 8 he'd gotten all of his information -- the case 9 agent or the attorney, the primary person at the10 DOJ, you said they got all their information from11 Bill Browder. Can you tell us who that was and who12 conducted the interview?13 MR. LEVY: Mr. Simpson should definitely14 answer that question. I just want to make sure for15 the record that he hadn't finished his answer. He16 can talk more extensively about the litigation17 support that he provided for Baker --18 MR. FOSTER: We're happy to get into that if19 he wants to do that. We're just coming up at the20 end of our hour.21 MR. LEVY: No problem.22 MR. FOSTER: and I wanted to get that23 follow-up in before --24 MR. LEVY: No problem. No problem at all.25 BY THE WITNESS:Page 49￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼1 A. I'll just finish with one last thing and 2 I'm happy to answer that question. 3 So in the course of this, you know -- I mean, 4 one of my interests or even obsessions over the 5 last decade has been corruption in Russia and 6 Russian kleptocracy and the police state that was 7 there. I was stationed in Europe from 2005 to 2007 8 or '8. So I was there when Putin was consolidating 9 power and all this wave of power was coming. So10 it's been a subject that I've read very widely on11 and I'm very interested in the history of Putin's12 rise.13 You know, in the course of all this I'll tell14 you I became personally interested in where Bill15 Browder came from, how he made so much money under16 Vladimir Putin without getting involved in anything17 illicit. So I read his book and I began doing18 other research and I found filings at the SEC19 linking him quite directly and his company, Salomon20 Brothers at the time, to a company in Russia called21 Peter Star, and I had, as it happens, vetted Peter22 Star and I knew that Peter Star was, you know, at23 the center of a corruption case that I covered as a24 reporter at the Wall Street Journal. When I went25 back into the history of Peter Star I realized that

1 Bill Browder did business with the mayor's office 2 in Saint Petersburg when Vladimir Putin was the 3 deputy mayor and was responsible for dealing with 4 western businessmen and corporations. 5 I then went and looked in Red Notice, this 6 was a large deal, it was the biggest deal ever for 7 Salomon at that time, they sold $98 million worth 8 of stock on NASDAQ. There's no mention of William 9 Browder's deal with Peter Star in Red Notice. I10 can't tell you why, but I can tell you that Peter11 Star later became the subject of a massive12 corruption investigation, Pan-European, that I13 exposed a lot of and that led to the resignation of14 Putin's telecoms minister. So I assume he might15 not have -- this is kind of a pattern with Browder,16 which is he tends to omit things that aren't17 helpful to him, and I think we've seen a good bit18 of that lately in his allegations against me, which19 I'm sure you're going to ask me about.20 So your question about the ICE agent, he was21 deposed by John Moscow of the New York office of22 Baker Hostetler. John is an old associate of mine23 from my days as a journalist. John's an expert on24 tax evasion and money laundering. He was the head25 of the rackets bureau for the district attorney'sPage 511-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 office in New York. 2 MR. FOSTER: You're talking about a formal 3 deposition in the litigation? 4 MR. SIMPSON: Yeah. 5 MR. FOSTER: I just wanted to clarify that. 6 MR. SIMPSON: Again, it's in the court 7 record. One of the frustrating things about this 8 whole issue for me is everything I'm talking about 9 or most of it is in the court record. You know, I10 don't take a lot of credit for my work. So you11 won't see my name scattered through the court12 record, but a lot of this is what I did.13 MR. DAVIS: I think that's concludes our14 first hour. Let's take a short break before we15 begin a new one.16 MR. FOSTER: Let's go off the record.17 MR. DAVIS: We'll go off the record at18 10:45.19 (A short break was had.)20 MS. SAWYER: It's about 10:55.21 EXAMINATION22 BY MS. SAWYER:23 Q. Mr. Simpson, again, I'm Heather Sawyer, I24 work as counsel for Senator Feinstein, and I have25 with me two of my colleagues. I will primarily bePage 52￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 asking the questions. They may have some2 follow-up. 3 We want to make sure we're clear. So 4 certainly if I ask you a question, anything that's 5 unclear, let me know and I will clarify it. Again, 6 we appreciate you being here today to answer our7 questions. 8 You had talked with my colleagues a bit about 9 the work that Fusion GPS does in general and I10 wanted to ask you some follow-up on that. What11 would you describe as kind of the key expertise of12 your firm, Fusion GPS?13 A. Public information is our specialty. We14 generally are all ex-journalists and specific type15 of journalists, investigative reporters, and, you16 know, being a journalist is all about finding17 public information. At least, you know, the kind18 of journalism I practiced was based on documents.19 I'm a document hound and so are my colleagues.20 So essentially we gather up large quantities21 of public information and we process that. We've22 sort of more recently branched into data science23 and, you know, digital data, obtaining databases24 through FOIA. We do a lot of Freedom of25 Information Act work. We work with court recordsPage 53￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 a lot, corporate records a lot. Some of my 2 employees do a lot of financial crime and money 3 laundering and fraud investigations, tax evasion, 4 that sort of thing. Those are my specialties. 5 I was also a political reporter and covered 6 campaigns and elections. I know a lot about how 7 campaigns work and how, you know, Washington works 8 generally. So we do things like policy disputes, 9 one industry versus another, one company versus10 another. We don't do a lot of campaign consulting,11 but every four years for the last couple of cycles12 we've done some presidential work.13 Generally speaking, the way our business is14 structured most campaigns don't have the budget for15 the kind of services that we provide. So we only16 would do things where people have the resources to17 pay for a serious piece of research. So we do18 things like a California initiative or19 presidential.20 Q. And how would you describe like how would21 you pitch and why would a client need your22 services?23 A. Generally speaking, people tend to get24 referred to us when they have a sort of undefined25 need, like they feel like they don't know whatPage 54￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 happened or they don't know what happened, they 2 don't know what's going on. So I think that's what 3 I referred to earlier as the decision support part4 of our work. 5 You know, a client will come to us and 6 they'll say I'm being sued and they're accusing me7 ofXand,youknow,notonlydidInotdoit,butI 8 don't even understand why they're suing me. I 9 mean, that's a kind of typical thing. Also another10 example would be I think I've been defrauded, but I11 can't figure out how or why. Or I keep -- you12 know, I run the best company in my industry and,13 you know, we make the best widgets and we keep14 losing out on the Pentagon contract to this other15 guy and we think something fishy's going on and we16 want you to help us figure it out.17 Q. So in some ways it's fact gathering and18 due diligence for clients?19 A. Well, it is certainly fact gathering and I20 certainly am around the due diligence industry and21 I am essentially part of it, but we don't really do22 a lot of classic due diligence, which has become a23 commoditized product in the business intelligence24 field that is conducted, you know, at a fairly sort25 of low level. it's become sort of a mass productPage 55￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 like a McDonald's cheeseburger. 2 Q. I think when you were speaking with my 3 colleagues you described your work as open ended 4 and not results directed. Can you explain a little 5 more what you mean by that? 6 A. Sure. Another thing we say about our work 7 is it's custom information, it's a customized 8 product. You tell us what your problem is and we 9 customize a research solution. In general when10 people come to us and they tell us what their11 challenge is, we stipulate that they retain us for12 30 days, they agree to pay our fee, they don't tell13 us what to do, they don't tell us, you know, what14 result to get. I like to call it a holistic15 methodology.16 The reason we do it that way, you know, A, we17 are professionals and we feel like it's not helpful18 to have someone dictating how you do things, but,19 B, if you predetermine the result that you're20 looking for you tend to miss things. So it's21 better -- you know, it's pure versus applied22 science, right? You're looking to understand how23 things work before you understand what you might24 need to address a particular problem.25 What happens after you've done open-endedPage 56￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 57 1 research is then, of course, you try to apply it to 2 the specific issues at hand. So if you're not able 3 to get a government contract and you think the 4 other guy is up to something and we find out, you 5 know, indeed he's been making, you know, payments 6 to somebody, you know, then we would, you know, 7 advise them on how to address that. 8 Q. So the way it's structured you are 9 certainly free to follow the facts wherever they10 may lead you in the course of research?11 A. That's right. You know, it's a little12 different in litigation where you're working for an13 attorney and he's got specific things he needs,14 like serving a witness or something like that, but15 on the research side of it it's -- I have the16 professional -- basically I reserve for myself the17 professional freedom to find out the answers.18 Q. A January 11, 2017 New York Times article19 described your firm, Fusion GPS, as a firm that20 "Most often works for business clients, but in21 presidential elections the firm is sometimes hired22 by candidates, party organizations, or donors to do23 political oppo work, short for opposition research24 on the side."25 Is that an accurate description of the firm?￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 A. In a shorthand way, yeah. I mean, it's 2 consistent with the description I think I gave you. 3 We don't do a lot of campaign work, but, you know, 4 every few years we do. And most of our clients are 5 not trying to win an election. They're trying to 6 win a lawsuit or, you know, find out who ripped7 them off. 8 Q. With regard to the political or campaign 9 work that you do, the same principles you've talked10 about in terms of how the relationship is11 structured, how the research is done, do those same12 principles apply to that political or campaign13 research as well?14 A. Yes. There's a limited number of examples15 because we don't do a lot of it, but, again, my16 specialty is really sort of financial17 investigations and business practices. In the18 last -- you know, in a current example we have a19 businessman who had a far-flung business empire all20 around the world. So, you know, that was a natural21 subject for me. So we do, we investigate22 multinational enterprises on a frequent basis.23 Q. Just to be clear, when you say "in the24 current example," what are you referring to?25 A. 2016 presidential election.Page 58￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. And then, by extension, when you'retalking about an international businessman, Ipresume you're talking about then candidate nowPresident Trump?A. Yes.Q.Ido want to ask you more about that, but before we get to that, in general, when you do the political or campaign work you're equally free to follow the facts wherever they lead you and the firm Fusion GPS? A. Yes, that's right. Q. Now, certainly it sounds like you handlebusiness for multiple clients, not just one clientat one time. How do you handle the fact that youhave work for more than one client in terms ofprotecting confidentiality in general andensuring -- well, first of all, I presume that youtake steps so that work for one client is notshared with another client? MR. LEVY: What's the question? MS. SAWYER: Do you take steps to ensure thatwork that you're doing for one client is not sharedwith another client?BY THE WITNESS: A. Yes. My partners and I don't talkPage 59￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 60 1 about -- it's like a lawyer wouldn't talk about one 2 client to another client. You know, there's some 3 exceptions when things become public. If we're 4 working on a public matter and someone else asks us 5 about it, I mean, obviously if it's public it's not 6 -- it doesn't need to be protected. But we have 7 systems to segregate our cases and clients and, you 8 know, we deal with them individually and we operate 9 in that sense, you know, like a lawyer would.10 As the business has grown, you know, we've11 taken on more and more matters. So I don't -- you12 know, I generally do about a half a dozen cases at13 a time on all range of subjects in all parts of the14 world, and the same is true of my partners and we15 divide them up. So sometimes we work together, but16 frequently each of them will be doing three, four,17 five cases at a time.18 Q. With regard to subcontractors who work19 with the firm, do you have a policy that is shared20 with them about how they are to treat the21 information that they're doing on behalf of one of22 your clients vis-a-vis some of your other clients?23 A. Well, our subcontractors are governed by24 NDA's to start with. In most cases that I can25 think of we don't have one subcontractor working on￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 more than one matter, but to the extent that would 2 happen, we don't really -- when you're dealing with 3 subcontractors you're giving them generally very 4 specific assignments, find out what you can about 5 this company or this businessman or this court 6 case, whatever, and a lot of that you never get 7 into who the client is. It's irrelevant. 8 I'd say more often than not the 9 subcontractors don't know who the client is. We10 would not volunteer that information to them unless11 they were what we would call a super sub, which is12 someone who, you know, has worked with us for a13 long time and has enough trust and confidence to be14 involved. Again, it would also be on a kind of15 need-to-know basis. There's no need for a16 subcontractor to know who a client is unless it's17 for, you know, KYC, know your customer kind of due18 diligence purposes. Sometimes we identify clients19 to prevent conflicts. So unless there's a reason20 like that or because they need to meet with the21 client, you know, we generally wouldn't tell them22 who the client is.23 Q. So you had mentioned a few minutes ago24 that you had done some political or campaign25 research in the course of the 2016 presidentialPage 61￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 election and you clarified that that was work 2 related to then Candidate and now President Trump. 3 What can you tell us about that work? Can you just 4 describe it first generally and then I'll ask you 5 some follow-up. 6 A. It was, broadly speaking, a kind of 7 holistic examination of Donald Trump's business 8 record and his associations, his bankruptcies, his 9 suppliers, you know, offshore or third-world10 suppliers of products that he was selling. You11 know, it evolved somewhat quickly into issues of12 his relationships to organized crime figures but,13 you know, really the gamut of Donald Trump.14 What we generally do at the beginning of a15 case if it's possible is to order all the books16 about the subject from Amazon so we're not17 reinventing the wheel and we know what's been18 written and said before. So this was typical. We19 ordered every Donald Trump book and, to my20 surprise, that's a lot of books. I was never very21 interested in Donald Trump. He was not a serious22 political figure that I'd ever had any exposure to.23 He's a New York figure really.24 So anyway, we read everything we could read25 about Donald Trump. Those books cover hisPage 62￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

divorces, his casinos, his early years dealingswith labor unions and mafia figures. I'm trying tothink what else. His taxes certainly have alwaysbeen a big issue. Again, it was sort of anunlimited look at his -- you know, his business andfinances and that sort of thing. Q. And when did this work begin? A. It was either September or October of2015. I recall being in London on other businessand hearing somebody wanted for us to take a lookat it. Q. And what can you tell us about who engagedyou initially to do that work? MR. LEVY: The answer to that question mightimplicate privilege.BY MS. SAWYER: Q. So it has been publicly reported that theinitial engagement of September to October 2015 wasby someone with ties -- with Republican ties. Canyou confirm whether that is accurate or not? MR. LEVY: We're not going to talk about theidentity of clients.BY MS. SAWYER: Q. So with regard to this engagement inSeptember -- that began initially in September orPage 63￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 October 2015, what were you asked specifically to 2 do by the client? 3 A. I don't have specific recollection of 4 there being a specific tasking. I believe it was 5 why don't you take a look at Donald Trump, it looks 6 like he may, you know, be more successful than 7 people think, something -- there was some level of 8 insight that he had a better shot than people were 9 giving him at the time, but it was on open-ended10 request like most of the things that we get.11 Q. And, again, on that one was the work12 directed at all by the client? Did they ask you to13 look at any particular aspects of Candidate Trump's14 background?15 A. I don't -- I know there was --16 MR. LEVY: We're not going to get into client17 communications. It's privileged.

BY MS. SAWYER: Q. Were you in any way limited in theresearch that you did or the facts that you wantedto pursue? A. Can I talk generally about my practicesand the history? Q. Sure. A. I mean, in general it's very rare forPage 64￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 someone to tell me look here, don't look there.2 For the most part we are looking at -- you know,3 we're trying to understand something big. So it's4 really counterproductive for somebody to tell you5 look here, don't look there, I'm interested in X6 but not Y. So we generally sort of push back when7 that happens, but I have to say we sort of set the8 rules at the beginning and people, you know,9 accepted those terms. So generally that's what we10 explain to people in the beginning of our11 engagements, you know, let us do our jobs and12 that's the way it works best.13 Q. And did that -- can you tell us whether14 that general practice and rule applied to the15 engagement that you took on in September or October16 2015 with regard to Candidate Trump?17 MR. LEVY: You can answer that without18 getting into client communications.19 BY THE WITNESS:20 A. I mean, we were -- it was regular order.21 As, you know, various people will tell you, I'm --22 you know, it would be like herding a cat, right?23 We're going to do what we do. So it was regular24 order.25Q. And then when you spoke with my colleaguesPage 65￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 66 1 earlier you had indicated that sometimes when facts 2 are gathered you present options to a client and 3 you articulated kind of four options, a potential 4 lawsuit, take it to a government agency, give it to 5 Congress, give it to the press. Did you -- were 6 those the general options on the table with regard 7 to this engagement as well? 8 MR. LEVY: If you can discuss it without 9 talking about client communications. If you can't,10 you can't.11 BY THE WITNESS:12 A. I'm just trying to -- because it evolved13 it's a little bit hard to -- I mean, in the14 beginning of this case like pretty much every case15 there was no -- there was no range of options --16 there weren't -- it was a request to see what we17 could find out about Donald Trump and the, you18 know, goal or sort of reason, there wasn't really19 one. It was tell me what we need to know about20 this guy. So later on, you know, we started21 getting press inquiries and at that point, you22 know, the sort of press element enters the23 equation, but I can't really get into what they24 told me or didn't tell me to do.25 Q. And are you free today to talk to us about￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 any of the actual findings from that research and 2 that engagement?3 A. Yes. 4 Q. Okay. So with regard to that initial 5 engagement because you had talked a bit about some 6 of the research you had done -- I think you said it 7 was holistic, financials, potential ties to 8 organized crime. With regard to this initial 9 engagement that started in October, September, can10 you just explain for us what your findings were.11 A. I guess I'll just give you the caveat12 that, you know, it's a group effort. So I can tell13 you, you know, as the person that was, you know,14 running the project, you know, I had my fingers in15 various things, but there were also the things that16 I was directly focused on.17 In the early -- the very first weekend that I18 started boning up on Donald Trump, you know, I19 found various references to him having connections20 to Italian organized crime and later to a Russian21 organized crime figure named Felix Sater,22 S-A-T-E-R. It wasn't hard to find, it wasn't any23 great achievement, it was in the New York Times,24 but as someone who has done a lot of Russian25 organized crime investigations as a journalistPage 67￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 originally that caught my attention and became 2 something that, you know, I focused on while other 3 people looked at other things. 4 So from the very beginning of this organized 5 crime was -- Russian organized crime was a focus of 6 interest. I guess I should just repeat, you know, 7 this is a subject that I covered extensively at the 8 Wall Street Journal. I wrote a series of front- 9 page articles about various corrupt politicians10 from Russia, oligarchs, and one of the things that11 I wrote about was the connections between western12 politicians and Russian business figures. So, you13 know, I was sort of an amateur student of the14 subject and I had written about some of these same15 Russian crime figures, you know, years earlier in16 the U.S. and various frauds and things they were17 involved in.18 As it happens, Felix Sater was, you know,19 connected to the same Russian crime family that was20 at issue in the Prevezon case, which is the21 dominant Russian crime family in Russia and has a22 robust U.S. presence and is involved in a lot of23 crime and criminal activity in the United States24 and for many years was the -- the leader of this25 family was on the FBI most wanted list and livesPage 68￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 openly in Moscow as a fugitive from U.S. law for a 2 very elaborate stock fraud. 3 Q. Who is that individual and family? 4 A. The first name is Semyon, S-E-M-Y-O-N, the 5 last name is Mogilevich, M-O-G-I-L-E-V-I-C-H. 6 Mogilevich is sometimes referred to as the brainy 7 Don because he runs very sophisticated schemes 8 including, according to the FBI, involving natural 9 gas pipelines in Europe, and he's wanted in10 connection with an elaborate stock fraud called YBM11 Magnex that was took place in the Philadelphia12 area.13 You know, Russian organized crime is very14 different from Italian organized crime. It's much15 more sort of a hybrid kind of thing where they're16 involved in politics and banking and there's even a17 lot of connections between the mafia and the KGB or18 the FSB and cyber crime, things that the Italians19 sort of never figured out. Stock fraud in20 particular was the big thing in the U.S. In any21 event, all of that entered into my thinking when I22 saw that Donald Trump was in business with Felix23 Sater in the Trump Soho project and a number of24 other controversial condo projects.25 Q. And what, if anything, did you concludePage 69￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 about the connection between and in the business 2 dealings that then Candidate Trump had had with3 Mr. Sater? 4 A. Well, somewhat analogous to the Browder 5 situation I found it notable this was something he 6 didn't want to talk about and testified under oath 7 he wouldn't know Felix if he ran into him in the 8 street. That was not true. He knew him well and, 9 in fact, continued to associate with him long after10 he learned of Felix's organized crime ties. So,11 you know, that tells you something about somebody.12 So I concluded that he was okay with that and that13 was a troubling thing. I also, you know, began14 to -- I keep saying I, but we as a company began to15 look at where his money came from and, you know,16 that raised a lot of questions. We saw indications17 that some of the money came from Kazakhstan, among18 other places, and that some of it you just couldn't19 account for.20 You know, we also conducted a much broader21 sort of look at his entire career and his overseas22 investments in places like Europe and Latin23 America. You know, it wasn't really a Russia24 focused investigation for the first half of it.25 That was just one component of a broader look atPage 70￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 his business career, his finances. We spent a lot 2 of time trying to figure out whether he's really as 3 rich as he says he is because that was the subject 4 of a libel case that he filed against a journalist 5 named Tim O'Brien for which there was quite a lot 6 of discovery and litigation filings detailing 7 O'Brien's allegation that he was worth, you know, 8 maybe a fifth to a third of what he claims and 9 Trump's angry retort that he was worth far more10 than that.11 So we did things like we looked at the golf12 courses and whether they actually ever made any13 money and how much debt they had. We looked at the14 bankruptcies, how could somebody go through so many15 bankruptcies, you know, and still have a billion16 dollars in personal assets. So those are the kinds17 of things. We looked at a lot of things like his18 tax bills. Tax bills are useful because you can19 figure out how much money someone is making or how20 much they're worth or how much their properties are21 worth based on how much they have to pay in taxes.22 One of the things we found out was that, you23 know, when it comes to paying taxes, Donald Trump24 claims to not have much stuff. At least the Trump25 organization. So they would make filings withPage 71￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

various state and local authorities saying thattheir buildings weren't worth much. Q. And this information that you gathered,was it shared with the client that you had for thatSeptember, October engagement? A. I can't answer that. MS. QUINT: When you said you looked at thegolf courses and bankruptcies, just to clarify,everything you're talking about was for that 2015engagement? When you say it wasn't Russia focusedat first, I'm unclear of the time. MS. SAWYER: Yeah. Can you tell us when thatengagement ended? MR. LEVY: Which question is pending? Canyou repeat the question? MS. QUINT: I think they're related. I losttrack when you said you looked at golf courses,bankruptcies, tax bills and it was not initiallyRussia centric. I'm wondering the time frame tomake sure we're all on the same page. MR. SIMPSON: It's difficult to specificallyrecall when we did exactly what. For example, thespecific issue of the golf courses I think did comeup later, much later, but these things run instages. For instance, in the early stage of anPage 72￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 investigation, you know, particularly of Donald 2 Trump you want to get every lawsuit the guy's ever 3 been in. So, you know, we collected lawsuits from 4 around the country and the world. And I do 5 remember one of the earlier things we did was we 6 collected a lot of documents from Scotland because 7 he'd been in a big controversy there about land 8 use. There had been another one in Ireland. There 9 was a lot of Freedom of Information Act requests10 and that sort of thing.11 So in the early phases of something you're12 collecting lots of paper on every subject13 imaginable. So in the course of reading that14 litigation we would follow up on things that were15 interesting, such as a libel case against a16 journalist that he settled, which, in other words,17 he didn't prevail in his attempts to prove that he18 was a billionaire.19 BY MS. SAWYER:20 Q. So one way to help clarify this is just21 to -- you know, we had been talking about an22 engagement that began in September or October of23 2015. Can you tell us when that particular24 engagement ended?25 A. I can only estimate it.Page 73￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 Q. And in general when do you think that2 ended? 3 A. Spring of 2016. 4 MR. LEVY: Don't guess. 5 MR. SIMPSON: I'm sorry. 6 BY MS. SAWYER: 7 Q. Okay. But that engagement did come to an 8 end and it came to an end before November 8th, the 9 election, November 8, 2016?10 A. It did end before the election, yes.11 Q. And then did you continue doing opposition12 work on Candidate Trump -- then Candidate Trump,13 now President Trump for a different client?14 A. Yes.15 Q. And can you tell us generally when that16 engagement began?17 A.Itwasin the first half of 2016.18 Q. And what, if anything, can you tell us19 about that client?20 A. Nothing.21 MR. LEVY: Not nothing as a factual matter,22 but he's going to decline to answer that question.23 MS. SAWYER: And the basis again for24 declining that question?25 MR. LEVY: Privilege.Page 74￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MS. SAWYER: Okay. MR. LEVY: And other obligations ofconfidentiality. MS. SAWYER: Just to be clear for the record,specifically what privilege? MR. LEVY: The privileges that we previouslyasserted with the committee. They're in ourApril 7 and June 23 letters. MS. SAWYER: Okay.BY MS. SAWYER: Q. With regard to the engagements, both ofthese engagements to do opposition research onCandidate Trump, were you paid directly by each ofthe clients or was there an intermediary payingyou? A. I think I'd like to confer with my lawyerabout this. MR. LEVY: Sure. (Whereupon a discussion was had sotto voce.) MR. SIMPSON: I'm going to decline to answerthat question. MS. SAWYER: And, again, the grounds fordeclining? MR. LEVY: It's a voluntary interview and itPage 75￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 would implicate privileges and obligations that 2 we've set forth with the committee potentially. 3 MS. SAWYER: Sure. 4 BY MS. SAWYER: 5 Q. At a news briefing on August 1, 2017 White 6 House Press Secretary Sarah Huckabee Sanders 7 described Fusion GPS as a democratic linked firm. 8 Is that an accurate description? 9 A. I would not agree with that description.10 I was a journalist for most of my adult life and a11 professional at not taking sides, and I'm happy and12 proud to say I have lots of Republican clients and13 friends and I have lots of Democratic clients and14 friends. I've lived in this city for 30 years or15 so and I know a lot of people on both sides and we16 have a long proud history of not being partisan.17 And the same is true for my colleagues. We18 intentionally don't hire people who have strong19 partisan affiliations. We prefer journalists who20 don't see things through ideological prisms and21 ideological prisms are not helpful for doing22 research.23 Q. So it has been widely reported that you24 engaged Christopher Steele to do part of the25 research, the opposition research on CandidatePage 76￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Trump. Is that accurate? A. Yes. Q. And he was working in that capacity as asubcontractor for you? And when I say "you" here Imean Fusion GPS.A. Yes. Q. And when did you engage Mr. Steele toconduct opposition research on Candidate Trump? A. I don't specifically recall, but it wouldhave been in the -- it would have been May or Juneof 2016. Q. And why did you engage Mr. Steele in Mayor June of 2016? A. That calls for a somewhat long answer. Wehad done an enormous amount of work on Donald Trumpgenerally at this point in the project and we beganto drill down on specific areas. He was not theonly subcontractor that we engaged. Other parts ofthe world required other people. For example, wewere interested in the fact that the Trump familywas selling merchandise under the Trump brand inthe United States that was made in sweat shops inAsia and South America -- or Latin America. So weneeded someone else for that. So there were otherthings. We were not totally focused on Russia atPage 77￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 that time, but we were at a point where we were -- 2 you know, we'd done a lot of reading and research 3 and we were drilling down on specific areas. 4 Scotland was another one. 5 So that's the answer. What happens when you 6 get to this point in an investigation when you've 7 gathered all of the public record information and 8 you've begun to exhaust your open source, you know, 9 resources is that you tend to find specialists who10 can take you further into a subject and I had known11 Chris since I left the Wall Street Journal. He was12 the lead Russianist at MI6 prior to leaving the13 government and an extremely well-regarded14 investigator, researcher, and, as I say, we're15 friends and share interest in Russian kleptocracy16 and organized crime issues. I would say that's17 broadly why I asked him to see what he could find18 out about Donald Trump's business activities in19 Russia.20 Q. So in May or June 2016 you hired21 Christopher Steele to, as you've just indicated,22 find out what he could about Donald Trump's23 business activities in Russia. Did something in24 particular trigger that assignment?25 A. No, I don't think I could point toPage 78￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 something in particular as a trigger. I mean, the 2 basis for the request was he had made a number of 3 trips to Russia and talked about doing a number of 4 business deals but never did one, and that struck 5 me as a little bit odd and calling for an 6 explanation. 7 You know, in the background of all 8 international business is questions about 9 corruption. The Trump organization had branched10 out all over the world in like the four to eight11 years prior to 2016. So in any kind of12 investigation you would naturally want to know13 whether there was some issue with improper business14 relationships.15 I'll just stress that we weren't looking16 for -- at least it wasn't at the forefront of my17 mind there was going to be anything involving the18 Russian government per se, at least not that I19 recall.20 Q. So at the time you first hired him had it21 been publicly reported that there had been a cyber22 intrusion into the Democratic National Convention23 computer system?24 A. I don't specifically remember. What I25 know was that there was chatter around WashingtonPage 79￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 80 1 about hacking of the Democrats and Democratic think 2 tanks and other things like that and there was a 3 site that had sprung up called D.C. Leaks that 4 seemed to suggest that somebody was up to 5 something. I don't think at the time at least that 6 we were particularly focused on -- well, I don't 7 specifically remember. 8 Q. So you hired Mr. Steele. Had you worked 9 with him before?10 A. Yes.11 Q. And can you generally describe what he had12 done in the capacity of working with you and your13 firm, what kind of projects?14 A. Generally speaking, like me, Chris tends15 to work for lawyers who are attempting to assist16 clients in litigation or an asset recovery-type17 situation. And so, you know, the former Soviet18 Union throws off an enormous number of disputes19 about who owns what because of the history of state20 ownership of everything and the transfers of21 property into private hands following the collapse22 of the Soviet Union was a murky process. So23 particularly in Europe there's a lot of disputes24 over who really owns what.25 And so we would collaborate on those kinds of￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 investigations. Sometimes a controversy would 2 spill over into the United States and, you know, I 3 would be asked to see if I could find a company 4 here or there or run director searches on 5 individuals who might be associated with people we 6 were interested in, that sort of thing. It's 7 interesting work, but it's kind of plain vanilla 8 business intelligence, litigation support stuff. 9 Q. And roughly how many years -- over how10 many years, like when do you first recall working11 with him?12 A. I believe we met in 2009. We've worked13 together since 2009.14 Q. And how did you find the quality of his15 work over that period of time?16 A. Quality is a really important issue in the17 business intelligence industry. There's a lot of18 poor quality work and a lot of people make a lot of19 promises about what they can do and who they know20 and what they can find out and then there's just a21 lot of people who operate in sort of improper22 questionable ways. Chris was, you know, a person23 who delivered quality work in very appropriate24 ways.25So -- I mean, I hope you won't be insulted,Page 81￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 but he's basically a Boy Scout. You know, he 2 worked for the government for a very long time. He 3 lives a very modest, quiet life, and, you know, 4 this is his specialty. We got along very well 5 because my speciality is public information. So he 6 was comfortable working with me and I was 7 comfortable working with him and, you know, we've 8 both been around a lot of criminal investigations 9 and national security stuff.10 When I was at the Journal I spent many years11 investigating the financing of Al-Qaeda. So I did12 get introduced to sort of national security law and13 national security operations and wrote a lot about14 that and was dragged into court over that a few15 times for things I wrote about people suspected of16 funding terrorism. So we had a lot of common17 interests and background.18 Q. And specific to the engagement with regard19 to the research on Candidate Trump, why did you20 specifically ask Mr. Steele to do that work?21 A. The way our firm runs we pursue things,22 you know, somewhat out of curiosity. So we didn't23 know -- it was opaque what Donald Trump had been24 doing on these business trips to Russia. We didn't25 know what he was doing there. So I gave Chris --Page 82￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 we gave Chris a sort of assignment that would be 2 typical for us which was pretty open ended. We 3 said see if you can find out what Donald Trump's 4 been doing on these trips to Russia. Since Chris 5 and I worked together over the years there's a lot 6 that didn't need to be said. That would include 7 who is he doing business with, which hotels does he 8 like to stay at, you know, did anyone ever offer 9 him anything, you know, the standard sort of things10 you would look at. I don't think I gave him any11 specific instructions beyond the general find out12 what he was up to.13 Q. And was anyone else -- did you engage14 anyone else to do that particular research?15 A. In Russia?16 Q. Yes.17 A. So we had other people like Ed Baumgartner18 who, you know, by this time -- I guess Prevezon was19 still winding down, but who would do Russian20 language research which didn't involve going to21 Russia. It just involves reading Russian newspaper22 accounts and that sort of thing.23 Q. So was Mr. Baumgartner also working on24 opposition research for Candidate Trump?25 A. At some point, I think probably after thePage 83￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

end of the Prevezon case we asked him to help withI think -- my specific recollection is he worked onspecific issues involving Paul Manafort andUkraine. Q. With regard to the presidential electionof 2016?A. Yes. Q. We had talked about work for multipleclients. What steps were taken, if any, to makesure that the work that Mr. Baumgartner was doingfor Prevezon was not shared across to the clientsyou were working for with regard to thepresidential election?A. He didn't deal with them. He didn't deal with the clients. There wouldn't have been any reason to -- he operates under the same rules that Ido. Q. And with regard to Mr. Steele, did he everdo any work for Fusion GPS on the Prevezonlitigation matter?A. No. Q. It's my understanding that Mr. Steeleworks with a company called Orbis & Associates.Did anyone else at Orbis, to the best of yourknowledge, work with Mr. Steele on the engagementPage 84￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

that you had with him related to Candidate Trump? A. I mean, I don't know their names. Q. So do you know whether anyone else workedwith him? A. Yes. I mean, do you mean assubcontractors or within his company? Q. First within his company. MR. LEVY: If you know.BY THE WITNESS: A. I mean, I just don't remember their names.I remember meeting somebody in London who I thinkworked on it, but I just don't remember. Q. Somebody else associated with Orbis? A. Yes. Q. With regard to the assignment that yougave to Mr. Steele to do Russia-related researchfor Candidate Trump, is that an accurate way todescribe it? I said Russia-related research withregard to Candidate Trump. Would that be a fairway to describe the assignment?A. Yes. Q. Did you have any input into the actualwork that he did? Did you give him directions asto what to research specifically? A. I don't recall giving him specificPage 85￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 instructions. We spoke on the phone about various 2 areas of interest. For example, when Paul Manafort 3 was elevated to running the campaign, we talked 4 about Paul Manafort and his long history of 5 dealings with Russian oligarchs. So it's more of a 6 collaboration than, you know, sort of manager- 7 employee kind of relationship. You know, we would 8 talk about things that were interesting to us and 9 that seemed to be -- you know, needed to be10 (indecipherable).11 Q.Soisit fair to describe it as you would12 collaboratively discuss potential topics to13 explore?14 A. Yes, I think that's fair.15 Q. And did you conduct any of the actual16 research yourself?17 A. Well, I think it's important to understand18 we were doing in my company, you know, all kinds of19 research, including lots of Russia research, and20 part of what you do when you get information from21 someone outside the company who's specifically22 looking at a discrete set of questions or issues is23 you add it to the stuff you've already gathered.24 So we did all kinds of stuff on public information25 about Donald Trump's business trips to Russia andPage 86￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 business dealings with Russians. I mean, Chris's 2 role was specifically to do the thing that we 3 couldn't do, which was to arrange to talk to 4 people. Generally speaking, we don't do a lot of 5 interviewing. Our research is very document6 focused. 7 Q. So to the extent you can describe, when 8 you say he was doing something you could not do and 9 that was he was arranging to talk to people, can10 you describe who it was he was reaching out to,11 what you knew about that?12 A. I don't think for security reasons, among13 other things, it's an area I'm not going to be able14 to go into in terms of sources and things like15 that. I think speaking broadly, you know, there's16 a large diaspora of Russians around the world and17 people in Moscow that, you know, are talking to18 each other all the time. The thing that people19 forget about what was going on in June of 2016 was20 that no one was really focused on sort of this21 question of whether Donald Trump had a relationship22 with the Kremlin.23 So, you know, when Chris started asking24 around in Moscow about this the information was25 sitting there. It wasn't a giant secret. PeoplePage 87￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 were talking about it freely. It was only, you 2 know, later that it became a subject of great 3 controversy and people clammed up, and at that time 4 the whole issue of the hacking was also, you know, 5 not really focused on Russia. So these things 6 eventually converged into, you know, a major issue, 7 but at the time it wasn't one. 8 Q. I have five or so more minutes and I know 9 that I have a lot more questions just about some of10 that work, but I do want to just pin down a couple11 things about the engagement in particular before we12 end this hour.13 So with regard to selecting Mr. Steele14 specifically to do the Russia -- to do work on15 Candidate Trump's ties to Russia, do you believe16 based on his experience and background that17 Mr. Steele would have been aware of the potential18 in his discussions with these people that he could19 be fed this information?20 A. When Chris -- I don't believe it, I know21 it. When Chris briefs in a sort of more formal22 setting, which I've seen, you know, when he23 introduces himself -- you know, he was the lead24 Russianist for MI6. So the first sort of beginning25 of that is he says, you know, I've worked on thisPage 88￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 issue all my life and when you're trained in 2 Russian intelligence matters the fundamental 3 problem of your profession is disinformation. It's 4 the number one issue. 5 In any collection of field -- you know, 6 information from the field you should assume that 7 there will be possibly some disinformation and 8 that, you know, as a professional who has dedicated 9 my life to this, you know, I am trained to spot10 possible or likely disinformation. So it's front11 and center when you gather information in Russia.12 Q. And when you hired him to do the work, did13 the client -- were you still working for -- at any14 time did you work for two clients on this15 opposition research? Did they overlap, the two16 clients?17 A. I just don't know. I can just tell you18 that it was -- I mean, things follow the political19 cycle. So there was a point at which the20 Republican primaries were fundamentally over and21 the Democrats hadn't really begun yet. So there22 was some transition period. That's all I can say.23 I don't keep the books at my place. So I would24 feel -- I'm afraid to give you a wrong answer that.25 I just don't know.Page 89￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 Q. Did either client know that you had hired 2 Mr. Steele specifically? 3 A. I don't think I can answer that. 4 Q. And on what basis can you not answer that? 5 MR. LEVY: The answer to that question 6 would -- could require the disclosure of client 7 communications which might implicate privileges and 8 obligations that we've previously set forth to the9 committee.10 BY MS. SAWYER:11 Q. Okay. Maybe you can answer this question,12 then. Did either client ever direct Mr. Steele13 themselves, directly engage and have conversations14 with Mr. Steele?15 A. I don't think I can answer that.16 MR. LEVY: Do you want to take a break?17 MR. SIMPSON: Sure.18 MR. LEVY: Let's take a break and confer.19 MR. SIMPSON: That's fine.20 MS. SAWYER: Sure. We'll go off the record21 for a few minutes.22 MR. FOSTER: It's 11:51.23 (A short break was had.)24 MR. FOSTER: It's 11:53.25 MS. SAWYER: I think the question pending wasPage 90￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 just whether or not the clients specifically spoke 2 with or directed Mr. Steele's work? 3 MR. LEVY: So he can't talk about client 4 communications, directions to the client -- 5 directions to Mr. Steele as those communications 6 might implicate privilege or obligations, but if 7 you want to ask him whether the clients directed 8 Mr. Steele to go to the FBI, that's a question he 9 can answer. That's in the scope of the interview10 today.11 BY MS. SAWYER:12 Q. All right. So we'll get to that. We'll13 talk about that a little bit later. Let me just14 follow up on a couple other things that came up and15 then we'll conclude for our hour and turn it back16 to our colleagues.17 So one of the things that came up in the18 course of our conversation and when I had asked you19 specifically about work being done for one client20 and rules and procedures in place to ensure that21 that work is not shared with another, can you just22 specifically describe those rules. I think at one23 point you indicated that you and Mr. Baumgartner24 had operated under the same rules?25 A. Right. We're both professionals and wePage 91￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

both deal with multiple clients. So we don't talkabout a case with one client with another client. I think since you raised this I should beclear, Mr. Baumgartner did not know aboutMr. Steele, the work I was doing with Mr. Steeleor, you know, the memos he was writing. MR. FOSTER: Can you speak up a little bit.BY THE WITNESS: A. Mr. Baumgartner did not know about thework that we were doing with Mr. Steele. One ofthe ways that we avoid bleeding between one caseand another is compartmentalization. We don't tellpeople -- we don't tell one subcontractor whatwe're doing with another subcontractor. We don'teven tell them, you know, that they exist. Q. What about Mr. Steele, what rules was heoperating under when he was doing the work onCandidate Trump? A. Every subcontractor signs an NDA at thebeginning of the discussion before even there's anengagement. So he was operating under an NDA. Q. And in general what does that NDA provide?And by NDA I assume you mean nondisclosureagreement? A. Right. Again, the paperwork side of thePage 92￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 business is not my strong suit, but it's a general 2 strict prohibition on sharing information about the 3 nature of the work you're doing, your findings with 4 anyone outside of, you know -- we're the client in 5 this case. So they're not allowed to share 6 information with anyone outside the case. 7 Q. And you had talked a bit about prior work 8 and Mr. Steele's performance in prior work and 9 being satisfied by that work. Did you do anything10 to kind of test and make sure that information he11 was giving you was accurate?12 A. So in the sort of -- I know I'm repeating13 myself, but generally we do public records work.14 So we deal in documents and things that are very15 hard and that are useful in court or, you know,16 other kinds of proceedings.17 Chris deals in a very different kind of18 information, which is human intelligence, human19 information. So by its very nature the question of20 whether something is accurate isn't really asked.21 The question that is asked generally is whether22 it's credible. Human intelligence isn't good for,23 you know, filing lawsuits. It's good for making24 decisions and trying to understand what's going on25 and that's a really valuable thing, but it's notPage 93￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 the same thing. 2 So when you evaluate human intelligence, 3 human reporting, field reporting, source reporting, 4 you know, it's sort of like when you're a 5 journalist and you're trying to figure out who's 6 telling the truth, right. You don't really decide 7 who's telling the truth. You decide whether the 8 person is credible, right, whether they know what 9 they're talking about, whether there's other10 reasons to believe what they're saying, whether11 anything they've said factually matches up with12 something in the public record.13 So, you know, we would evaluate his memos14 based on whether he told us something we didn't15 know from somewhere else that we were then able to16 run down. So, you know, for example, he, you know,17 wrote a memo about a Trump campaign advisor named18 Carter Page and his mysterious trip to Moscow.19 Q. I'm just going to stop you for a moment20 because I hadn't yet gotten to the specific stuff21 of the Trump assignment. I was just trying to get22 a sense of the specific ways in which you assessed23 his performance in determining to hire him.24 A. That's how we did it. We would assess it25 based on the content and the credibility of -- we'dPage 94￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

try to determine the credibility of what we werereading. MR. MUSE: His reference was to give you anexample. I think that's where he was going. MR. SIMPSON: Yeah. MS. SAWYER: I understand and I appreciatethat and we'll get to that. I just didn't wantto -- in light of the time I didn't want to get youstarted down that road. If I could just have asecond because I want to make sure we finish ourquestions on this topic and we'll resume our nexthour with some of the others. MR. SIMPSON: Okay. MS. SAWYER: So we'll go off the record.It's high noon, 12:00. So let's go off the record. (A short break was had.) MR. DAVIS: We're back on the record. It's12:06 p.m.EXAMINATIONBY MR. DAVIS: Q. All right. Mr. Simpson, I'm going toreturn to the topic of Prevezon. Let me know ifI'm accurately summarizing the scope of work you'redescribing. I think you've described three mainareas so far. First is that you were investigatingPage 95￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 Prevezon's side of the story to see if it was 2 credible; the second is you were investigating Bill 3 Browder's ties to the U.S. and related subpoena 4 issues; and the third is that you were 5 investigating Bill Browder's Russian businesses. 6 Is that correct? 7 MR. LEVY: I think he said a lot more than 8 that, but go ahead. 9 MR. DAVIS: I listed the main topics. That's10 where we left off.11 MR. LEVY: I don't think that's the main12 topics either, but go ahead.13 BY THE WITNESS:14 A.Isthata yes-or-no question? I think15 those are three things I covered, but I covered a16 lot of stuff.17 Q. With the information that you gathered in18 those and related efforts, what did you do with the19 information once you obtained it?20 A. Well, the first thing you do is you give21 it to the lawyers and, you know, when appropriate22 you give it to reporters, you know, put it in court23 filings.24 Q. So is it correct, then, people associated25 with Fusion did communicate with journalists aboutPage 96￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 97 1 the Prevezon case and the information you found out 2 about Mr. Browder?3 A. Yes. 4 Q. And did Fusion engage in these 5 communications with the media on its own accord or 6 were you directed or authorized to do so? 7 A. In litigation support, you know, basically 8 the cases that we work on frequently get some media 9 attention. So it's always part of a litigation10 engagement that if you're the guy that does the11 research, you're going to end up talking to12 reporters because they're going to ask questions13 about, you know, information from the case.14 MR. LEVY: Just make sure you answer his15 question. Was it done?16 BY THE WITNESS:17 A. That's part of what the lawyers hire you18 to do and that's what they instruct you to do. The19 way it generally happens is the lawyer gets a call20 from a reporter who wants to write a story about21 the case and he answers the questions or gives them22 a quote and then he instructs me to give him23 background information.24 Q. So then was it typically done on a25 case-by-case basis or did you have blanket￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 authorization regardless of specific interactions 2 with the attorneys? 3 A. These things evolved over time. So in the 4 beginning of the case when you're new to a subject 5 you're generally fielding -- you generally get 6 requests from the lawyers to answer a specific 7 question that a reporter has. So the reporter will 8 call and they'll want to know whatever, where the 9 house was in Colorado, and he'll say somewhere in10 Aspen, ask Glenn. Then he'll send him to me or11 he'll send me to them. Later on when you get where12 you've gathered a mass of information that covers a13 whole wide range of topics and, you know, if14 there's more coverage, you know, they will direct15 you to answer questions for the reporters covering16 the case. They won't tell you on an individual17 basis talk to so-and-so. It's a little of both.18 Q. Was Fusion then paid for these19 communications with the media?20 A. We were compensated for our litigation21 support and as part of that we were directed to22 talk to the media. So in the fundamental sense23 yes, we were. Specifically paid for individual24 conversations, I don't think so.25 MR. FOSTER: Do you bill hourly?Page 98￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MR. SIMPSON: It depends on the case. MR. FOSTER: On this case? MR. SIMPSON: I think we did on this case. MR. FOSTER: So did you bill forconversations with the press on this case? MR. SIMPSON: I'm sorry to say I don't know.I probably did not. Generally speaking, what Iwould bill for would be to attend events wherethere would be press. So if I was at a courthearing -- most of the press was around courthearings. So I would go to a court hearing withthe lawyers and there would be reporters there. Sopart of what I was billing for was answering theirquestions.BY MR. DAVIS: Q. And with which news organizations didFusion communicate in relation to the Prevezoncase? A. I will try to remember them. It was themajor news organizations that were covering thelitigation. Usually it was their courthouse orlegal reporters. So it was Bloomberg, New YorkTimes, Wall Street Journal, probably Reuters, Legal360. I'm sure there were a handful of others. Q. Was the Financial Times possibly one ofPage 99￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼Page 1001 them?2 A. Yes. 3 Q. Politico? 4 A. They approached us with -- they had been 5 getting information from Bill Browder. He had 6 alleged to them that we were part of a big campaign 7 on Capitol Hill and that we were engaged in 8 lobbying and that it was all designed to affect 9 legislation or smear him or Sergei Magnitsky. So10 eventually we did end up dealing with that, but I11 don't remember whether we dealt with them prior to12 that. I don't think they covered the case prior to13 that.14 Q. What about NBC?15 A. We would have -- I'm sorry. Yes.16 Q. And the New Republic?17 A. I think so.18 Q. And do you recall what information you19 provided to each or is that too into the weeds?20 A. I don't know if it's in the weeds, but21 generally speaking, the work -- we provided22 information about the work that I had done about23 William Browder's credibility. The whole case24 ended up -- when I said when he declined to appear25 voluntarily as I am here and explain things, you1-800-FOR-DEPOhttp://www.aldersonreporting.com

1 know, it ended up being an issue of why he didn't 2 want to talk. So a lot of it was about his 3 credibility, about his account of his activities in 4 Russia, about his history of tax avoidance, all 5 these things. 6 Q. Did Fusion provide the media information 7 alleging that Browder had illicitly engineered the 8 purchase of 133 million shares of Gazprom? 9 A. I don't know for sure, but we certainly10 did research on that issue.11 Q. And you described investigating these12 series of issues. How did you acquire the13 information in the course of this investigate?14 A. We used the methods that I've described15 here today. We pulled court records, we pulled16 corporate records, we, you know, pulled real estate17 records, SEC securities filings, that sort of18 thing.19 Q. And was any of the information you20 provided to the media information that wasn't the21 result of your own research but that had been22 passed along to you by Baker Hostetler or Prevezon?23 A. I think the answer to that is yes, but I'm24 struggling to think of a specific example. As I25 was saying earlier, the lawyers did a lot of the1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 research too. So there was obviously a sharing of2 research where, you know, we were feeding research3 to them and they were housing a central repository4 of research and then the research would become5 memoranda and given in court filings. In a lot of6 these cases we were giving people court filings.7 So the information was mixed together from various8 sources. 9 Q. Did Fusion independently verify the10 information provided by Baker Hostetler or Prevezon11 or in this circumstance was it assumed to be12 reliable given your work with them?13 A. We certainly did not independently verify14 everything that the lawyers generated in the case.15 That would have been an enormous task and it would16 have made no sense.17 I just want to stress that I've worked with18 Baker Hostetler for -- you know, since 2009, so I19 guess going on over eight years, and they're very20 good lawyers and very conservative. So if they21 provided me with information that they had22 gathered, I would have been confident -- I was23 confident in the quality of their work.24 Q. And did Prevezon or Baker Hostetler ever25 direct Fusion to relay to the media informationPage 102￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

that they had provided to Fusion? A. I'm sorry. Can you say that again. Q. Did Baker Hostetler or Prevezon directFusion to relay to the media information that theyhad provided to you? A. I don't specifically recall an example ofthat, but I think as a general sort of operatingprinciple we were working at their direction andthey were providing us with, you know, caseinformation. So I think so, but I just don't havean idea. Q. And did anyone at Fusion or perhapsMr. Baumgartner review Russian documents related tothe Prevezon matter? A. Yes. Q. Do any -- A. Most of them were Russian courtdocuments. Q. Do any Fusion employees or associatesspeak Russian? A. No. I'll qualify that. Depends on howyou define associate. Edward isn't an employee ofthe company, but he speaks Russian. He's asubcontractor. Q. Aside from Mr. Baumgartner, do you havePage 103￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 104 1 any other support from Russian-speaking individuals 2 in reviewing the Russian documents? 3 A. Not in my company, at least not that I can 4 recall. There was other Russian speakers I think 5 that were engaged by Baker Hostetler in various 6 situations, like translators, Russian bilingual 7 lawyers, that sort of thing. 8 Q. Do you remember the names of any of those9 people?10 A. Anatoli, whose last name I can't really11 pronounce, was a New York-based English-Russian12 court translator. He was mostly a courtroom13 translator. So I don't know whether he -- I really14 don't know the extent of their other involvement15 with other people in these things.16 MR. FOSTER: Can I just back up before we get17 too far afield of this. I want to follow up on an18 answer that you gave earlier. You described your19 interactions with the press as primarily being20 directed to answer questions, in other words, the21 contact as being initiated by the press. That's my22 understanding of how you described it.23 MR. LEVY: I don't think that's a complete24 summary of what he said.25 MR. FOSTER: Feel free to correct me if I'm￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 wrong. My question is were there instances where2 you were initiating contact with the press or3 pitching stories to the press?4 MR. SIMPSON: Sure. I mean, the range of 5 things that you would do, you know, again, it would 6 evolve. In the beginning you were going to a lot 7 of hearings and a lot of legal reporters are 8 showing up and you're mostly answering their 9 questions. Depending on the setting, you know, you10 might get a question for the lawyers like is anyone11 from Reuters going to be there and you would reach12 out to Reuters and say are you guys sending someone13 to this hearing. So there was definitely some14 reach out like that. Then we would also talk to15 reporters, you know, generally covering issues of16 corruption or law or Russia or whatever and say,17 you know, we're involved in a really weird court18 case, you might be interested in this.19 MR. FOSTER: So is it fair to say that part20 of your job, then, was to locate reporters who21 would write about these matters from a point of22 view that was advantageous to your client?23 MR. SIMPSON: Yes, but I think we should note24 here that William Browder is an especially25 aggressive media self-promoter and promoter of hisPage 105￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 story. So for much of this case it was reactive2 and we were constantly besieged with reporters3 pursuing negative stories about Prevezon, the4 events of the Prevezon case that had been given to5 them by William Browder. So, you know, unhappily,6 I would say, you know, a lot of what we were doing7 was simply responding to his wild allegations,8 unsupported wild allegations. 9 There were certainly moments, particularly10 concerning his unwillingness to appear for a11 deposition, where we said to some reporters, hey,12 guy, you know, he's just dodged his third subpoena,13 you might want to write about this, it's pretty14 funny. In fact, you know, the third one he ran15 down a street in Manhattan in the middle of a16 blizzard to get away from our process servers, but17 that one we actually had them film it.18 So, you know, did we want to get that19 covered, did we think it was important that people20 know that this guy was unwilling to appear in court21 in public under oath to talk about the story that22 he'd been selling for years about his activities in23 Russia? Yeah, we wanted people to know that.24 BY MR. DAVIS:25 Q. Other than the media and Baker Hostetler,Page 106￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 did Fusion provide any information regarding the 2 Prevezon matter to any other third parties? 3 A. I don't have a specific recollection of 4 doing so. If there's a specific incident that 5 you'd like to ask about I'd be happy to try and 6 answer that. I don't remember. 7 Q. We'll get into that a little bit more. 8 Also to go back to the translator you 9 mentioned, you said Anatoli and that you didn't10 know how to pronounce --11 A. Samochornov I think is his --12 Q. Okay.13 A. I'm massacring it. Again, it's something14 that's in the public record.15 Q. Do you know Rinat Akhmetshin?16 A. Yes, I do.17 MR. MUSE: Spell it.18 MR. DAVIS: Sure. R-I-N-A-T,19 A-K-H-M-E-T-S-H-I-N.20 BY MR. DAVIS:21 Q. When did you first meet Mr. Akhmetshin?22 A. When I was a reporter at the Wall Street23 Journal.24 Q. And as far as you know, what is his25 business?Page 107￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 108 1 A. Some kind of PR consulting lobbyist. I 2 think he's a registered lobbyist. 3 Q. Have you ever worked with Mr. Akhmetshin? 4 A. I've been -- in the Prevezon case I 5 interacted with him. I think -- again, this has 6 unhelpfully been distorted by William Browder into 7 some sort of economic relationship or conspiracy or 8 something. I don't have any economic relations 9 with him. You know, I've bumped into him over the10 years around town. So, you know, the only thing11 that I specifically recall having done with him was12 interacting for a brief period on the Prevezon13 case.14 Q. You don't recall working with him for any15 other clients or cases?16 A. Let's be clear, I'm sure we did not do17 business together, but I do work on areas of the18 world where he's from, Central Asia, former Soviet19 Union, and he is, as I'm sure you've seen, a guy20 around town who knows lots of people who cover this21 stuff. I met him in connection with some stories I22 was doing on Kazakhstan at the Wall Street Journal.23 That's the kind of context I've bumped into him24 over the years. He's told me various things and I25 think I even met one of his clients at one point,￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 but it wasn't a business thing. I don't think I2 was doing any work. I was just networking.3 Q. You said he told you various things. Do4 you mean he would pass along information to you?5 A. The information that I remember was about6 his Kyrgyzstan stuff. There was a congressional7 investigation into Kyrgyzstan that he claimed8 credit for having started and he told me about it9 for some reason, but it wasn't because we were10 doing business together. It was coffee or11 something.12 Q. You said he claimed credit for having13 started the congressional investigation?14 A. That's my recollection, but this was some15 years ago.16 Q. And you said you met one of his clients.17 Do you remember which client?18 A. A former Kazakh politician whose name19 escapes me.20 Q. Do you remember when you met that client?21 A. Years ago in London.22 Q. Has Mr. Akhmetshin ever been paid by23 Fusion GPS?24 A. Not to my knowledge.25 Q. Has he ever provided information to FusionPage 109￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 110 1 GPS for use in your work? 2 A. I don't have a specific recollection of 3 him having done so. I would hesitate to say so 4 categorically because I've been running this 5 business now for a number of years and I would have 6 interacted with him at various times and ways that 7 I probably don't remember, but not that I 8 specifically recall. 9 Q. Has Mr. Akhmetshin ever paid Fusion GPS10 for work?11 A. Not to my knowledge.12 Q. You mentioned interacting with him in the13 Prevezon matter. What did you understand his role14 to be in the Prevezon work?15 A. I did not have a clear understanding of16 his role initially. He started attending meetings17 sometime in 2016, just a handful of things, and18 it's -- you know what? I don't recall anyone ever19 saying to me you're not doing X, Y, or Z. They may20 have. I just don't recall. The lane that I was in21 was the court case and this fight over whether22 Browder would have to testify, which morphed then23 into this fight over whether -- you know, his24 allegations that John Moscow had a conflict of25 interest. So I was very focused on that. These￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 other issues came up two plus years into the case2 and he was clearly dealing with them, but I don't3 recall anyone sort of giving me a specific4 explanation, you know, of what he was doing.5 MR. FOSTER: What other issues?6 MR. SIMPSON: The issues of the -- what do7 you call it, HRAGI, the foundation and the8 congressional stuff.9 BY MR. DAVIS:10 Q. You mentioned he started showing up at11 meetings in 2016. Who else attended these12 meetings?13 A. I don't specifically remember. I mean, Ed14 Lieberman I think was at a meeting. Again, I don't15 think it was -- it wasn't a lot of meetings, just16 one or two, but it was at Baker Hostetler.17 MR. FOSTER: Can you explain briefly who Ed18 Lieberman is.19 MR. SIMPSON: Ed Lieberman is a lawyer in20 Washington who has a specialty in international tax21 who worked for Baker Hostetler on some of the22 analysis of the alleged tax evasion by Hermitage23 Capital and William Browder. And then subsequently24 also he knows Rinat from I guess, I don't know,25 college or something and subsequently the two ofPage 111￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

them were working on the -- I don't know what tocall it, the congressional stuff. MR. FOSTER: Lobbying Congress? MR. SIMPSON: I believe they registered tolobby Congress.BY MR. DAVIS: Q. Did Fusion provide any of its research toMr. Akhmetshin whether directly or through anintermediary such as Baker Hostetler? A. Yes. We were directed to do so by BakerHostetler. Q. And do you know or have reason to believewhether Mr. Akhmetshin used that information whenhe spoke with people on the Hill? A. I have reason to believe that. I don'thave specific knowledge of his discussions withpeople on the Hill. I don't remember. He may havetold me what he did. As I say, it was not thefocus of my work. Q. Has Mr. Akhmetshin ever said anything toyou indicating or implying that he had worked withthe Russian government? A. Well, I knew he had been a soldier, I knewhe had been in the Soviet military, and I also knewthat he went to Moscow a fair bit because he saidPage 112￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 on several occasions I'm in Moscow or I'm going to2 Moscow. He may have -- I don't recall whether he3 mentioned having worked with the Russian4 government.5 Q. Has he ever said anything to you6 indicating or implying that he had worked for7 Russian intelligence more specifically?8 A. Well, as I said, I'm sure that he had9 mentioned to me maybe back in, you know, the time10 when I was at the Wall Street Journal that he was11 in the Soviet military and he had some kind of12 low-level intelligence position, but I don't13 remember anything beyond that. He certainly didn't14 say anything in recent years about having any15 current connections with Russian intelligence.16 Q. Has he ever said anything to you17 indicating or implying that he has contacts or18 connections with Russian government officials?19 A. Not that I specifically recall.20 Q. Do you have reason to believe that he has21 ties to the Russian government?22 A. I have reason to wonder whether he has23 ties to the Russian government, but, you know, in24 the course of my work for Baker Hostetler the25 question of whether he had some connection to thePage 113￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DCRussian government wasn't germane really. It justdidn't come up. Obviously with the news of thismeeting at Trump Tower and the allegations in themedia that there's some relationship there I shareeveryone's interest in the answer to thatquestion. Q. Do you know Natalia Veselnitskaya? A. Yes. Q. When did you first interact withMs. Veselnitskaya? A. I believe it was sometime in 2014. Q. Has Fusion ever worked withMs. Veselnitskaya? A. Didn't I just answer that? Yes. I mean,she was the lawyer, the Russian lawyer who retainedBaker Hostetler who retained us. So when you say"worked with," I don't know that as a technicalmeaning, but we interacted with her as part of thePrevezon litigation. Q. Has Fusion ever been paid by her? A. Well, she arranged -- as the lawyer forPrevezon she would have arranged for Prevezon topay Baker Hostetler which paid us. So if that'swhat your question is, then the answer is yes, butI mean, I don't think the money came from her. ItPage 114￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 115 1 came from Prevezon. 2 Q. Were there any direct payments that didn't 3 go through Baker Hostetler?4 A. No. 5 Q. So what did you understand her role to be 6 in the litigation? You said she was the attorney 7 for Prevezon. Was she managing the case for8 Prevezon? 9 A. I was not introduced to her originally.10 The original way that she was -- it came up in my11 conversations with Mark Cymrot and other Baker12 lawyers was as the person who had hired them who13 had the information about the extortion case14 against Demetri Baranovsky. It was represented to15 me by Mark Cymrot that she handled that matter and16 was familiar with the prosecution of Demetri17 Baranovsky and very well versed in the events of18 the extortion. So, you know, that's how I learned19 of her and I think that's probably -- our first20 interactions were probably about that subject.21 Q. Did she provide Fusion with the22 information about that extortion case?23 A. Well, I certainly discussed it with her at24 some point, but it was all in Russian. You know,25 the bulk of the Russian-English translating just￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 for, you know, chain of evidence reasons went from2 her to Baker Hostetler. They would have materials3 analyzed and translated and then they would -- I4 don't read a word of Russian. So I would get the5 certified translations of stuff from Baker. 6 Q. And beyond your interactions with her 7 about the extortion issue, what type of interaction 8 did you have with her in the course of the Prevezon9 work?10 A. In the early period it was I believe11 largely about this extortion case. Later on when12 we would appear in court it would -- you know, she13 would come to some of the Court hearings and the14 issue of Browder's efforts to avoid having to15 testify were front and center, sort of the main16 issue for quite a while. So I don't remember17 specific conversations with her about that, but18 that's what we would have discussed.19 Q. Have you met in person with her on other20 occasions besides court hearings?21 A. I attended a couple client dinners and I22 think that's about it.23 Q. Do you recall when and where those would24 have been?25 A. I recall some of the when and the where.Page 116￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 There were a couple of dinners in New York and a2 couple of dinners in D.C. I don't remember when3 they started. I think probably 2015. And there4 was some in 2016 in both cities. 5 Q. Were any in June 2016?6 A. Yes. Two. 7 Q. Were those in New York or in D.C.? 8 A. I believe that one was in New York and one9 was in D.C.10 Q. Do you recall the specific date of either?11 A. I didn't until we tried to piece these12 things together, but June 8th I think was the13 dinner in New York and I think the 10th was the14 dinner in D.C., something like that.15 Q. And what were the purposes of these16 dinners?17 A. Well, the first one was just an obligatory18 client dinner which, you know, when you work on a19 legal case you get invited to dinner with the20 clients. The one in D.C. was more of a social21 thing. It wasn't -- she was at it, but it wasn't22 really about the case. It was just a bunch of Mark23 Cymrot's friends. You know, the editor of the24 Washington Post book section was there and his wife25 who's a well-known author were also there. I can'tPage 117￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

remember who else was there. But anyway, she satat the other end of the table from me and, youknow, as I said, she doesn't really speak Englishand I don't speak Russian. So not a lot ofchit-chat. Q. Was it your understanding that theresearch you provided to Baker Hostetler would thenbe passed on to Ms. Veselnitskaya? A. To the extent that it was useful andinteresting to her I'm sure they did, yes. Q. Has she ever said anything to you,presumably via a translator, indicating or implyingshe had worked with the Russian government? A. No, but Mark Cymrot told me when he toldme of her existence that she was a formerprosecutor. Q. And has she ever said anything to you morespecifically indicating or implying that she hadworked for Russian intelligence?A. No. Q. Do you have any reasons to believe thatMs. Veselnitskaya has ties to the Russiangovernment? A. I know what I've read in the newspaper. Q. Beyond that?Page 118￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 A. Beyond that my impression of her was of2 someone who, you know, was a very smart and3 ambitious lawyer, but not like a big political4 player in the Kremlin. Of course given to wonder5 given all the recent events and disclosures that I6 was unaware of whether my assessment of her was 7 right or wrong. As we sit here today, the jury's 8 kind of out. I honestly can tell you all I knew is 9 she didn't seem to be a heavy hitter in the Kremlin10 world.11 Q. This might be a little repetitive, but12 when did you first meet Ed Lieberman?13 A.I don't remember specifically, but it was14 years ago.15 Q.I believe you described his business.16 Have you ever worked with Mr. Lieberman?17 A. I don't think so.18 Q. Or Fusion more broadly?19 A. Not that I can recall.20 Q. Have you ever paid him or been paid by21 him?22 A. No.23 Q. And what exactly did you understand his24 role to be in the Prevezon issue?25 A. Well, the initial issue that we worked onPage 119￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 together was the issues about alleged tax evasion2 by Hermitage Capital in Russia and William3 Browder's decision to surrender his citizenship4 shortly before the tax rules on surrendering your5 citizenship changed, which tended to make us 6 suspect that it was motivated by tax 7 considerations. At that time we didn't know about 8 the offshore companies in BVI. 9 Q. And what type of interactions did you have10 with Mr. Lieberman in the course of the Prevezon11 work?12 A. Collegial, I guess professional I would13 say. Ed's, you know, got a background in tax. So14 we talked about tax stuff. Later on, much later on15 after a couple years had gone by, you know, he and16 Rinat embarked on this other project, but I don't17 have a specific recollection of whether I dealt18 with him directly on any of that.19 Q. Did Fusion provide its research to20 Mr. Lieberman either directly or through an21 intermediary such as Baker Hostetler?22 A. Not that I recall, but if the lawyers23 asked me to send them something, I would send them24 something.25 Q. Do you have any reason to believe thatPage 120￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Mr. Lieberman has ties to the Russian government? A. No. Q. Do you know Mr. Robert Arakelian,A-R-A-K-E-L-I-A-N? A. There was a guy at a lunch or dinner orsomething named Robert and he was introduced to meas Robert. Again, when you're going to like theseclient meals or things like that, you know, wedidn't get into a lot of details of who he was. Ijust remember he was introduced as a friend Denis1011 Katsyv, K-A-T-S-Y-V. That's my recollection. It

may be that he's a friend of Rinat's. I don'treally know.Q.Asfaras you know, what is Mr. -- what is Robert's business? A. I don't know. Q. So presumably, then, has Fusion everworked with him? A. Not to my knowledge. Q. What did you understand Mr. Arakelian'srole to be in the Prevezon work? A. I didn't know he had a role. If someonetold me I've forgotten, but, again, I was prettynarrowly focused on a few things and he wasn'tinvolved in those things.Page 121￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. Were you aware that he was a registeredlobbyist for HRAGI?A. No. Q. Other than meeting him at that dinner, didyou have any other interactions with him in thecourse of the Prevezon work? A. Not that I can recall. Q. Did Fusion provide any research to himdirectly or through an intermediary such as BakerHostetler? A. I don't know. I mean, if Baker Hostetlergave him information from my research or mycompany's research, they didn't tell me. Q. Do you have any reason to believe he hasties to the Russian government?A. No. Q. But you said he is friends with theKatsyvs? A. I shouldn't speculate. I recall he wasintroduced to me as a friend of someone and I don'tremember whether it was Rinat or Denis Katsyv, butit was one or the other. Q. Do you know Howard Schweitzer? A. I don't, not that I can recall. Q. So you've never done any business withPage 122￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

him; is that correct? A. I don't think so. Q. Do you know if he had any role in thePrevezon work? A. I've read that his firm was involved inthe lobbying, but it's just something I read. Idon't believe I had any personal interactions. Q. Do you know who Denis Katsyv is? A. He's the owner of Prevezon. Q. Did you have any interactions with him? A. Again, I sat in a few meetings, a coupleof client meals, but it was limited by his limitedEnglish and my limited Russian. Q. In your interactions withMs. Veselnitskaya did she claim to be acting as theattorney for Prevezon Holdings and the Katsyvfamily or just for Prevezon Holdings? A. She was introduced to me as the lawyer forPrevezon. I never -- MR. LEVY: When you say "the Katsyv family,"Denis Katsyv is the only person named in thelawsuit. I'm just wondering what you mean by that. MR. DAVIS: Denis or Pyotr. MR. SIMPSON: As I said, she was introducedto me as the lawyer for Prevezon. So -- and IPage 123￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

think the lawyer for Denis. So beyond that Idon't know.BY MR. DAVIS: Q. Do you know who Pyotr Katsyv is?A.Idonow. Imean,Iknewalittlebit about him at the time, but now that it's become an issue, at least in the mind of William Browder, obviously I know who he is. Q. Did you have any interactions with him? A. No. Q. Do you know Chris Cooper? A. Yes. Q. How long have you known Mr. Cooper? A. Probably ten years, maybe longer. Q. As far as you know, what is hisbusiness? A. Public relations. Q. Is he associated with the Potomac SquareGroup? A. I believe he is the Potomac Square Group. Q. Has Fusion ever worked with Mr. Cooper orthe Potomac Square Group?A. Yes.Q. Have you paid him or been paid by him?A. I believe we've paid him. I don't know ifPage 124￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 he's paid us.2 Q. What did you understand his role to be in3 the Prevezon work?4 A. He worked on his movie doing --5 essentially as I understand it and recall it, he6 was asked to help find a place where they could7 show this movie. William Browder likes to use the8 press, but he doesn't like anyone talking freely9 about him or raising questions about the story of10 his activities in Russia. So when this movie came11 together they were going to screen it in Europe and12 he hired the meanest libel firm in London which has13 previously sued me on behalf of Saudi billionaires14 and -- unsuccessfully I might add, and he15 threatened to file libel cases against the people16 who were daring to offer to host a showing of this17 film.18 So, as you know, they don't have the First19 Amendment in Europe. So he was able to20 successfully suppress the showings of this film21 which questioned his credibility and whether -- the22 truth of his story and his activities in Russia.23 So Chris came up with the idea of showing it at the24 Newseum which is dedicated to the First Amendment25 and where they don't have much time for libelPage 125￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 126lawyers and people trying to suppress free speech Q. And was the showing arranged for Prevezon,for HRAGI? Who was arranging this? A. I don't know. Q. Did Fusion have any role in that showing? A. We supplied some names of people. Theywanted to round up people who would be interestedin coming, journalists, friends, people interestedin Russia, and we supplied names for them. Q. Did Fusion contact any journalists toinform them about the film or the showing or toencourage them to write about it? A. I believe that I mentioned it to somejournalists in terms of showing up. I don'tbelieve I -- I just don't remember whether I triedto get anyone to write anything about it, but if Idid I would have had good reason to because it wasall about William Browder's credibility which wasthe subject that we were hotly litigating inNew York and I had been on this -- you know, we hadbeen on this, you know, multi-year effort to gethim to answer questions about his activities inRussia. So it was the central issue in thePrevezon case. Q. So you mentioned Mr. Cooper was involved￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 127 1 in establishing this screening. Do you know how he 2 came to be hired by Prevezon or HRAGI or whoever? 3 A. I know a little. As I was saying earlier, 4 I've known Chris from Wall Street Journal days and 5 I refer business to him. I know this doesn't fit 6 with the Browder theory of the case, but I don't do 7 a lot of public relations work and I refer, you 8 know, public relations jobs to other people,9 friends.10 So when the trial was approaching in the11 Prevezon case I kept telling the lawyers you guys12 have to hire a PR guy, I'm not going to do this,13 it's just too much work. So we were trying to find14 PR people and he was one of the people that I15 recommended as a trial PR guy. From there I don't16 have a clear sense of how he ended up working on17 the movie, but it wouldn't be surprising if they18 had his name from the previous referral.19 Q. Do you know who came up with the idea of20 creating HRAGI?21 A. I would be guessing. I just don't22 remember. Someone may have told me. I don't23 remember.24 Q. What kind of interaction did Fusion have25 directly or indirectly with HRAGI?￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

A. I remember hearing about it. I rememberRinat talking about it and maybe others. We werevery peripheral to this stuff and I don't rememberif I had any specific interactions with it. Idon't know if they had an office, I don't know ifthey had a bank account. I just don't know. I doknow they registered to lobby. Q. Do you know Lanny Wiles, L-A-N-N-Y,W-I-L-E-S?A.I know him a little bit. I met him originally when I was a journalist. He was introduced to me as a well-connected Republican consultant type and I bumped into him once or twice over the years. Q. Has Fusion ever worked with him? A. I don't think so, no. Q. What did you understand his role to be inthe Prevezon-HRAGI work? A. Again, my understanding of people'sroles on -- he was involved in the lobbying. He'sa lobbyist. He was involved in the lobbying.Beyond that I really couldn't say. Q. Did you have any involvement with him inthe course of your work on the Prevezon? A. I think we had lunch once.Page 128￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 Q. Do you have any reason to believe that2 Mr. Wiles has ties to the Russian government?3 A. No.4 Q. So as you mentioned, in 2016 people5 associated with HRAGI met and attempted to meet6 with people in a number of congressional offices.7 Were you aware of any of these meetings?8 A. The meeting that I was aware of that I9 remember hearing about was a meeting that actually10 didn't happen which was some meeting that Mark11 Cymrot was supposed to have. It's possible that he12 was going to meet some Congressman. It's possible13 that I was told about other meetings by some of14 these people that we're discussing, but I don't15 specifically remember hearing about other meetings.16 I was generally aware that there was stuff going on17 on the Hill.18 Q. If I could refer back to Exhibit 2, the19 partial privilege log. The first page of that20 document lists a 5/13/16 e-mail from Rinat21 Akhmetshin to Mark Cymrot with the subject/22 description "Appointment with Cong. Hill." Do you23 believe that to be a reference Congressman French24 Hill?25A. I don't know. I believe it was aPage 129￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Congressman named Hill. I don't know if it was aCongressman named French Hill. Q. And do you recall any other mentions ofmeetings with any particular congressional officesor committees? A. I'm sure -- I'm sorry. I believe I recallRinat telling me that he was talking to PaulBehrends, B-E-H-R-E-N-D-S. It was either Rinat orMark Cymrot or maybe both about some of theseissues, but, again, I don't have a greatrecollection for the specifics. Q. Did Fusion have any role in thesemeetings? A. I mean, I think we were asked forinformation, and to the extent that the lawyerswanted me to give somebody information I would handit over to them. It's their information. Q. To the best of your knowledge, was thatinformation referenced in the meetings withcongressional staff members? A. I don't know. Q. You mentioned you had dinner withMs. Veselnitskaya on June 8th and 10th of 2016.Were you generally aware of her trip to the UnitedStates in June?Page 130￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 131 1 A. I was. She had trouble getting a visa and 2 the lawyers -- there was some drama over whether 3 she could get a visa. This would have been a 4 recurring issue in the case. You know, our lawyers 5 believed that the Justice Department was 6 interfering with her visas because they wanted to 7 inhibit her from collaborating with us on the case, 8 but I don't have any independent knowledge of her 9 visa issues. I just remember that was an issue.10 I remember that at the last minute she got a11 visa to come to this Appellate Court hearing on12 June 9th in New York, and that was the way that she13 persuaded them to give her a visa was that she14 needed to attend a hearing which was on an appeal15 of a District Court ruling related to the16 disqualification motion that had been filed by17 William Browder against Baker Hostetler after he18 was ordered to give testimony.19 So that's the history of that court hearing,20 which was after the Court said he couldn't get out21 of the subpoena and he had to give testimony, he22 then triggered a new delay in his testimony by23 filing a disqualification motion.24 Q. And that hearing was on June 8th; is that25 correct?￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 A. I believe it was June 9th.2 Q. Did you have any other information about3 Ms. Veselnitskaya's itinerary or intended4 activities on this trip?5 A. No. I mean, I can tell you what I knew.6 I knew she was coming in I guess on the 8th. I7 don't have a clear recollection of the dinner, but8 I know -- I believe we had a dinner. The problem9 is I had more than one. So I don't have a clear10 recollection of it.11 Anyway, I saw her the next day in court at12 this hearing and I'm sure we exchanged greetings,13 but, as I say, she speaks Russian and I speak14 English. I think she was with Anatoli and she left15 afterwards. I know she didn't tell me any other16 plans she had.17 Q. So you had dinner the 8th, saw her in18 court on the 9th; is that correct?19 A. Yes.20 Q. And dinner again on the 10th?21 A. In D.C.22 Q. Did you see her any other time?23 A. Not that I recall.24 Q. Did Fusion play any role assisting25 Ms. Veselnitskaya during that trip?Page 132￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

A. Not that I recall. Q. It has widely been reportedMs. Veselnitskaya and Mr. Akhmetshin and others metwith Donald Trump, Junior, Paul Manafort, and JaredKushner on June 9th, 2016. Were you aware of thismeeting beforehand?A. No. Q. It didn't come up at the dinner the nightbefore?A. No. Q. When did you first become aware of themeeting? A. Around the time it broke in the New YorkTimes. I was stunned. Q. Is it correct that that means it wasn'tdiscussed at the dinner on the 10th? A. No, but, again, you know, the dinner onthe 10th was I was at one end of the table talkingto a woman about her biography on Simon Bolivar andshe was at the other end with Rinat and she doesn'treally speak much English. So, you know,fortunately I was not going to do a lot ofentertaining. Q. I should clarify, discussed with you. A. Yeah. So if she discussed with somebodyPage 133￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

else, I wouldn't -- Q. Right. Do you have any knowledge of the purpose ofthe meeting other than what you read in the media? A. No. No. Well, I mean, I read she wantedto give them some information and I wonderedwhether it was information from the Prevezon caseand I've seen speculation to that effect, but Idon't have any knowledge. Q. If we had the specifics of theinformation, would you be able to clarify whetherit had come from Fusion? A. I think so. If it's, you know, stuff Iworked on I obviously will recognize it, yes. Q. As far as you know, how was this meetingarranged or do you have any information beyondwhat's in the public --A. I don't. Q. Other than recent media reports, do youhave any reason to believe that the meeting was anattempt by the Russian government to make contactwith the Trump campaign? A. I mean, that's kind of an analyticalquestion. I don't have any factual reason tobelieve that. I don't have possession of anyPage 134￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

information about this that would allow me to sayone way or the other. You know, as a sort ofquestion of counterintelligence and just generalinvestigation of Russian methods and that sort ofthing, I think that's a reasonable interpretation. Q. Have you had any communications about themeeting at any time with Rinat Akhmetshin?A. No. No. Q. Have you had any communications about themeeting, again, at any time with Ms. Veselnitskaya?A. No. Q. Have you had any communications about themeeting with anyone you worked with on the Prevezonmatter? A. Probably. I think we all exchanged mutualexpressions of surprise. I think I talked to PaulLevine, a lawyer at Baker Hostetler. I'm sure Idiscussed it with Ed Baumgartner, Mark Cymrot. Youknow, if anyone knew about it they certainly didn'tconfess it to me. Q. Do you know -- I'm going to butcher thisname -- Irakle Kaveladze? A. I know who he is. Q. I'll spell it. I-R-A-K-L-E, last nameK-A-V-E-L-A-D-Z-E.Page 135￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 136 A. No, I don't know. Q. Has Fusion ever worked with him? A. No, not to my knowledge. Q. To the best of your knowledge, did he haveany role in the Prevezon or Magnitsky work? A. My knowledge is primarily of the Prevezoncase and, to my knowledge, he was not involved inthe Prevezon case in any way. Q. Do you have any reason to believe beyondpublic reporting that he has ties to the Russiangovernment? A. I've been told by a source that --actually, I was told by a source that there wassome reason to believe he had ties to the Russiangovernment, and he directed me to a newspaperarticle which said that he had connections to a guyon the West Coast named Boris Goldstein who hasbeen linked historically to Soviet Russianintelligence. Beyond that I don't have any -- Idon't have any information. Q. And who was the source that told you that? A. I'm not going to talk about my source. Q. I think you've already addressed this alittle bit, but do you know Anatoli Samochornov?A-N-A-T-O-L-I, S-A-M-O-C-H-O-R-N-O-V.￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 137 A. I met him in connection with this case.We've never had any kind of social or otherrelations beyond chatting in courthouses and thatsort of thing, sitting in restaurants waiting for ahearing to start. Q. Has Fusion ever worked with him other thanon the Prevezon case?A. No. Q. And to the best of your knowledge, whatwas his role in the Prevezon case? A. As I understood it, he was recruited offthe rack basically as a certified -- a translatorwho had courtroom experience in New York who wasqualified to do sort of technical-legal typetranslation work. He, to my knowledge, didn't havea pre-existing relationship with Ms. Veselnitskayaor Prevezon. That's my understanding to this day. MR. DAVIS: I think that's the end of ourhour. It is 1:04. Let's go off the record. (Whereupon, at 1:05 p.m., the interview was recessed, to reconvene at 1:45 p.m., this same day.) AFTERNOON SESSION MS. SAWYER: We'll go back on the record.￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

It's 1:55.BY MS. SAWYER:EXAMINATIONBY MS. SAWYER: Q. I'm going to return you back to discussingthe work at Fusion that Christopher Steele had doneduring the Presidential election of 2016. It hasbeen widely reported and Mr. Steele hasacknowledged that he created 16 memos before theelection between the time period of June of 2016and October of 2016. Is that accurate? A. To the best of my knowledge, that'saccurate. Q. And then he also has acknowledged --Mr. Steele also has acknowledged and it's beenreported that there was one additional memo thatcame after the election in December of 2016. Isthat also accurate? A. I think what he has said is that -- yeah,that's basically accurate. What he said was thatthe series of memos that were published byBuzzFeed, that's the package that you're talkingabout.(Exhibit 3 was marked for identification.)Page 138￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 139 1 Q. And so I'm going to show you what we will 2 just mark as Exhibit 3 for identification purposes. 3 So Exhibit 3 that I've just given you is a document 4 that was produced to the committee by your lawyers, 5 and they had explained to us that this was a 6 document originally posted by BuzzFeed in January 7 of 2017 and it has Bates numbers down in the 8 right-hand corner. The first one is 9 CLMS-JC-00041391 and then the last one is number10 41425. If you could just take a look at that. Is11 that what we were just discussing as the series of12 memos posted by BuzzFeed and created by Mr. Steele?13 A. Yes, it is.14 Q. Can you explain for us just what -- does15 this represent the 16 memos that would have16 occurred between June and October of 2016 that17 Mr. Steele created?18 A. These are the memos that he created under19 the engagement and then this extra one that is20 appended. I never actually numbered -- totaled21 them up, but these are the ones I'm familiar22 with.23 Q. And does this represent the entire24 universe of memos that Mr. Steele created as part25 of this particular engagement for you?￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 140 1 A. To the best of the my knowledge as part of 2 this engagement, this is it. 3 Q. And can you just explain to us so that we 4 understand the document, it has a heading "Company 5 Intelligence Report." I'm just looking at the 6 first page. That one says "Company Intelligence 7 Report 2016/080." What would that have signified? 8 A. Company Intelligence Report is just a way 9 of saying it's not a government document. In the10 event that, you know, someone stole it or it leaked11 or there was some sort of breach, you know, they're12 not going to have their own name on it, but they13 want to make sure that no one mistakes it for a14 government document. That's my understanding.15 080 is their internal numbering system for,16 you know, their production of memoranda, and the17 reason it jumps from 80 to 86 is -- I never18 actually asked him, but there aren't five memos in19 between this. So the interpretation is that it's20 an internal numbering system for maybe Russia stuff21 or maybe it's just -- I'm sorry. I don't know what22 the internal numbering system is, but there isn't23 five memos in this project between these two.24 Q. So the company referenced in Company25 Intelligence Report, your understanding is that￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

would be Orbis, not Fusion GPS? A. I can't answer that. I think it's, as Isaid, meant to denote that it's not a governmentreport.Q. Were they producing -- as you noted, the next apparent report 086 would be five, presumably, reports later. Were those other five reports reports that were being generated for Fusion GPS or--A. No. MR. LEVY: I don't think he said that. Goahead.BY THE WITNESS: A. I mean, there aren't five reports that hedid for us between these two. This is the firstand second. Q. So, again, when we look at that first onethat we discussed briefly, 2016/080, it appears tobe a three-page memorandum and it's dated 20 June2016 and that shows up on the last page. Would youhave received it around that time that it's dated,June 20, 2016? A. Within a couple days, yeah. Yes. Q. And not every single discrete memo has adate, but a number of them do. To the extent theyPage 141￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 142 1 had dates, would you have been receiving them 2 around the time they were dated? 3 A. Yeah. I believe so, yes. There might be 4 some lag, transition lag. 5 Q. And what was -- what use did you make of 6 these memos? 7 A. These memos -- I mean, I guess I'd like to 8 back up a little bit and explain, you know, what 9 led to the memos, which was -- as I said, I mean,10 you know, we started looking at -- first we started11 looking at Trump's business affairs generally with12 some of the emphasis on associations with organized13 crime and in particular Russian organized crime.14 As the project progressed towards the end of 201515 and into 2016 we became interested in his overseas16 business dealings particularly because they were so17 opaque and seemed to involve, you know, to say the18 least, colorful characters.19 So as we got into 2016 we were looking20 broadly at -- one of the things we were looking at,21 broadly speaking, was Donald Trump's international22 business dealings and, you know, through the spring23 of 2016, as I mentioned, we were -- you know, we24 looked in various places, Latin America. He has25 worked on projects all over the world, but in￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 particular, you know, several in the former Soviet2 Union, Georgia, Azerbaijan, both former Soviet3 republics. So over the course of the spring I'd4 say -- and Russia -- we gradually began to exhaust5 the public record, the open source about these6 topics in various places. As you, you know, sort7 of run short on public record or open source8 information, you know, you need to get -- if you9 still want to go deeper you need to get human10 source.11 So the purpose of this was to see if we could12 learn more, generally speaking, about his business13 dealings in Russia. What came back was something,14 you know, very different and obviously more15 alarming, which had to do with -- you know, which16 outlined a political conspiracy and a much broader17 set of issues than the ones that we basically went18 looking for. You know, initially we didn't know19 what do with this.20 The main thing we did with it, the use we21 made of it was as intelligence, which is to22 understand what's happening. So when this arrived23 the first indicators were starting to float around24 that there was something bigger going on, the25 government of Russia or someone was doing somePage 143￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 144 1 hacking. I don't really remember the precise 2 details. I just remember there were rumblings at 3 that time about whether there had been lot of 4 hacking and there was going to be -- political 5 digital espionage was going to be a component of 6 the campaign. 7 So when this arrived it was also right around 8 the time I think -- Trump had said weird things 9 about the Russians and Putin and things that are10 very atypical for a Republican and that people11 found to be odd. So when this arrived, you know,12 we made no immediate use of it at all in terms of,13 you know, giving it to anybody. It was essentially14 used to inform our other researcher, but because it15 was -- and because it was human source intelligence16 and some of it was of a personal nature, it was not17 particularly useful for the kind of things that18 are, you know, useful in politics, which are things19 that you can prove, things that you can say, things20 that people will believe.21 So we used it as intelligence to try and22 understand what was going on and, you know,23 obviously, as we talked about earlier, we tried to24 analyze this to see if it was credible. You know,25 I did -- you know, in the initial round of this￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 145 1 that was the big question, was this credible. 2 Q. Okay. So let me stop you there for a 3 second before we get too far because you've 4 referred a number of times to "this" and you have a 5 35-page document in front of you. So I want to 6 clarify when you said "this," in the context of 7 answering that I assumed you were talking about the8 first -- 9 A. The first memo.10 Q. That's the report 2016/080?11 A. Correct.12 Q. And that's the one that has the date of 2013 June 2016?14 A. Correct. To be totally clear, you know,15 what people call the dossier is not really a16 dossier. It's a collection of field memoranda, of17 field interviews, a collection that accumulates18 over a period of months. You know, they came in19 intermittently, there was no schedule. You know,20 he'd reach a point in the reporting where he had21 enough to send a new memo; so he'd send one. So22 you won't find any real rhythm or chronological23 sort of system to the way they came in.24 MR. MUSE: Just for clarification of "this,"25 there are bates numbers I think that could be￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 identified here. 2 MS. SAWYER: Right. So that first document, 3 the one that we've just been talking about, has 4 Bates Nos. 49391 to 41393. Do we need to go off 5 the record for a moment? Let's go off the record 6 for a moment. 7 (A short break was had.) 8 BY MS. SAWYER: 9 Q. With regard to this document, you10 characterized this document as representing field11 interviews, I think you talked about it as human12 source information. So was Mr. Steele's kind of13 role with regard to the project primarily14 conducting these types of interviews, gathering15 this type of what I think you referred to as human16 intelligence for Fusion?17 A. Yes. I mean, in other cases we did other18 things.19 MR. LEVY: Don't get into other cases.20 BY THE WITNESS:21 A. I can't remember specifically what I had22 in mind to get from him. This form of reporting23 was, in fact, the form that the rest of the project24 took, which was, you know -- I've done other kinds25 of research in Russia, but something this sensitivePage 146￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 147 1 I don't think I've ever been involved in. So in an 2 ordinary case you would try to gather public 3 records and you would conduct yourself in a much 4 more open fashion. 5 You know, Russia is a dangerous place, it's a 6 kleptocracy and a police state, but it's also a 7 giant bureaucracy and in some ways it's a much more 8 open society, much more open than the Soviet Union 9 ever was. You can pull records for companies and10 that sort of thing.11 Anyway, so this was unusual in what we were12 doing here and it's not what I had in mind when I13 asked him to begin collecting information on this.14 My expectation was of something a lot less15 interesting than this, more along the lines of a16 typical corruption investigation.17 Q. You had indicated that when you received18 it you found it unusual, it was sensitive19 information. Did you take steps to verify any of20 the information?21 A. We assessed it for credibility, whether it22 was credible. The question of the credibility of23 the information is obviously a big question here,24 can this be believed. There's other secondary25 questions that would follow on from that, can it￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 148 1 somehow be used, does it have any use and that sort 2 of thing, but the threshold question is is it 3 credible information. 4 You know, there were two background factors 5 to that. One was who is it coming from. It's 6 coming from Chris Steele who's a guy that I've 7 worked with for, you know, about eight or nine 8 years and Chris, as I say, has a Sterling 9 reputation as a person who doesn't exaggerate,10 doesn't make things up, doesn't sell baloney. In11 my business, I mean, there are a lot of people who12 make stuff up and sell baloney. So the one thing13 that you get good at if you do this for a while is14 finding reliable sources, finding reliable people15 who have a record of giving it to you straight and16 not making stuff up and not making mistakes. So17 from that perspective, you know, this was alarming18 because Chris is a credible person, he's well19 respected in his field, and, as I say, everyone I20 know who's ever dealt with him thinks he's quite21 good. That would include people from the U.S.22 government.23 So the issue is where is it coming from and24 then the other issue is does it make sense or are25 there events in there that can be externally, you￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 know, reviewed or backed up. On the question of 2 whether it makes sense -- well, let me stay on the 3 question of some of the events that are described. 4 We were aware of some of these trips and we were 5 obviously aware of the hostility toward Hillary 6 Clinton and, you know, there was a lot of general 7 knowledge that we had that fit with this just in 8 terms of dates and places and roles of people in 9 the Kremlin. So on a surface level, you know, it10 was credible too, but the thing that, you know,11 most concerned me at this point was my own12 familiarity with foreign meddling in American13 elections, which is a subject that I've dealt with14 for a long time.15 In the 1990s I was working at the Wall Street16 Journal and I wrote some of the very first stories17 about the Chinese government's interference in the18 1996 presidential election which triggered a19 massive national security investigation, numerous20 prosecutions, lots of business for Bob Muse, and a21 lot of congressional hearings, congressional22 inquiries. And in that episode it was eventually23 dug out by congressional investigations that the24 fundraisers, the Asian fundraisers were Chinese25 intelligence assets. So there's ample recentPage 149￼￼1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼Page 150 1 historical precedent for a foreign government to 2 interfere in American elections in a really big way 3 and for it to be an intelligence operation. So I 4 knew all of that while reading this and digesting 5 it for the first time. 6 I also knew because I've done a lot of 7 reporting on Russia about the Kremlin's interest in 8 American politics, European politics, disrupting 9 the politics of other countries, and, in fact, one10 of the last things I did when I was a reporter at11 the Wall Street Journal was report on several12 stories of government investigations, FBI13 investigations into American politicians who had14 been corrupted allegedly by the Russians.15 Sort of my departure point from journalism16 was a series of stories and conferences I attended17 where a lot of American and European intelligence18 officials were expressing great alarm at the19 resurfacing of Russian intelligence operations in20 western capitals and the new twist on it which21 seemed to be that these guys seemed to be getting22 involved in politics in ways that they hadn't23 previously. So I knew all that when I read this.24 Q. Okay. So if I can stop you there. It25 sounds like the components -- you can tell me if1-800-FOR-DEPOhttp://www.aldersonreporting.comAlderson Court Reporting

1 there were more -- that you considered in assessing 2 the credibility of this was Mr. Steele, his 3 background, his reputation, overall the fact that 4 you had information and knowledge of Russia 5 meddling in other countries' elections, and then 6 the broader work of Russia to disrupt political 7 systems of other countries? 8 A. I covered that. I also would add that the 9 China case was for me in my journalistic career a10 formative event that took -- you know, consumed11 years of my reporting and was about, you know, a12 Chinese intelligence operation to swing the '9613 election to the Democrats.14 The only other thing I'd add to all that is,15 again, in the mid 2000s one of the stories I16 wrote -- actually, I wrote a couple different17 stories about a Russian oligarch having a meeting18 with Senator John McCain shortly before the 200819 presidential election and another story or set of20 stories about Paul Manafort and his involvement21 with some Russian and Ukrainian oligarchs who were22 considered to be suspicious or corrupt.23 So I also knew -- or I formed an opinion or24 impression that the Russians were interested in25 making friends with the Republicans and that Paul1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 152 1 Manafort, you know, there was this previous episode 2 involving Paul Manafort, John McCain. So all of 3 that was in my head when this came in which, as I 4 say, tended to support the credibility -- the 5 possibility that this information was credible. 6 Q. You mentioned a Russian oligarch who had 7 met with Senator McCain. Who specifically was8 that? 9 A. Oleg Deripaska, O-L-E-G,10 D-E-R-I-P-A-S-K-A. He's not able to travel to the11 United States because he's banned for suspicion of12 ties to organized crime. He's extremely close to13 the Kremlin, or at least he was, and is -- I broke14 the story of him being banned from the United15 States which caused him a lot of embarrassment and16 trouble with his business and led to him hiring a17 lobbyist and trying to get involved with getting a18 visa to the U.S.19 Q. And you had also mentioned your background20 knowledge of Paul Manafort and his involvement with21 Russian oligarchs. Can you identify who those22 individuals were and the basis of that knowledge?23 A. The issue I specifically wrote about I24 believe was his work for the Party of Regions and25 Victor Yanukovych, Y-A-N-U-K-O-V-Y-C-H, I think,￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 153and that's the Pro-Russia party or was thePro-Russia party in Ukraine, and all that work sortof grew out of work I had done about the Kremlinworking with the Russian mafia to siphon money offthe gas trade between Russia and Ukraine. Q. Was that work you had done while still areporter with the Wall Street Journal?A. Yes. Q. So any conclusions you had reached fromthat, would that be material that we would be ableto obtain and may already have in your publicreporting? MR. LEVY: We'd have to talk to the WallStreet Journal about that probably.BY THE WITNESS: A. My articles about this are available onthe Internet. MR. LEVY: Some of them we've produced to youalready because it was responsive to your request. MS. SAWYER: Understood.BY MS. SAWYER: Q. And there's potentially additional workproduct related to the work that you had done onMr. Manafort? A. For the Wall Street Journal or later?￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. Let's start with the Wall StreetJournal? A. I collected lots of information onMr. Manafort during my years at the Journal. Q. And then we'll get into the work onMr. Manafort more recently. So this particular memo that we've beentalking about, this first one doesn't specificallymention, as far as I can see, any efforts tointerfere by Russia. It does talk aboutpotential -- as it's called in here, a dossier ofcompromising material on Hillary Clinton. Did youtake any steps to verify whether that dossier ofcompromising material existed on Hillary Clinton? A. I will answer that, but can I just backyou up a little bit. I think your observation itdoesn't mention anything about interfering Iwouldn't agree with.Q. Okay. A. I mean, one of the key lines here in thesecond paragraph says "However, he and his innercircle have accepted a regular flow of intelligencefrom the Kremlin, including on his democratic andother political rivals." So the issue with the Trump Tower meeting, asPage 154￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 I understand it, is that the Trump people were2 eager to accept intelligence from a foreign3 government about their political rivals and that4 is, you know, I would say, a form of interference.5 If you're getting help from a foreign government6 and your help is intelligence, then the foreign7 government's interfering. I mean, you know, I8 think that also -- of course, in retrospect we now9 know this was pretty right on target in terms on10 what it says. So anyway --11 Q. In reference to you think that particular12 sentence?13 A. I mean, it clearly refers to, you know,14 them being interested in and willing to -- it15 depicts them as accepting information. What we16 have seen to date with the disclosures this year is17 they were at a minimum super interested in getting18 information.19 Q. And when you're referencing the20 "disclosures this year," could you just be specific21 about that.22 A. The Trump Tower meeting.23 Q. So with reference to the June 9th Trump24 Tower meeting?25 A. Yes. Yes.Page 155￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. Okay. A. I will go back to your question, but,again, it says "Source B asserted the Trumpoperating was both supported and directed by Putinaimed to sew discord within the U.S.," and, youknow, basically -- you know, there's a number ofdifferent ways that it seems they're trying tointervene in our politics in this memo. What was your question? Q. I appreciate that clarification. You wereactually clarifying a statement I made, which Iappreciate. So you had testified a little earlier that atthe point in time in which you received this firstmemo you used it a little more as background toinform your thinking on it, but you didn't takediscrete steps. Had you -- were you involved inediting this memo in any way?A. No. Q. Did you give Mr. Steele any specificdirection on, you know, next steps based on thismemo? A. Not that I can recall, no. Q. So at this point in time was he stilloperating with the understanding that he was justPage 156￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

to engage in an open-ended research project? A. Actually it wasn't really an open-endedresearch project -- well, it was open-ended inscope, it wasn't open-ended in time. It was take afew weeks, see if there's anything there that'sinteresting, notable, important, and if we thinkthere's reason to go on we'll make that decision atthat time. So it was a short-term engagement inthe beginning. Q. And to the best you can explain to us, didthe client that you were working for know that hewas engaged in this particular research or what hisfindings were at that point in time? MR. LEVY: The answer to that question mightimplicate privilege or obligations.BY MS. SAWYER: Q. Did you interfere in any way withMr. Steele's research, tell him not to pursue anyparticular avenues?A. No. Q. To the best of your knowledge, did anyoneelse give him that direction, either directly orthrough you, and tell him not to -- A. No. Q. If I could just finish.Page 157￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

A. I'm sorry. Q. -- and tell him not to pursue anyparticular avenues of research?A. No. Q. Do you know -- if we could just move on tokind of the next memo, which begins with BatesNo. 41394 and it ends with 41396. It appears tobe -- it's three pages and it has a date of 26 July2015 and it has "Company Intelligence Report2016/086." To the best of your recollection, wasthis the second memo you had received fromMr. Steele? A. To the best of my recollection, this isthe second memo. Q. And how did you kind of use thisinformation? A. Well, I think the context of externalevents is important here. I believe -- it's myrecollection that what prompted this memo was, infact, the beginning of public reporting on thehack. I think -- what is the date again? Yeah,it's 26 July. So by this time Debbie WassermanSchultz has been the subject of a very aggressivehacking campaign, weaponized hack, the likes ofwhich, you know, have never really been seen.Page 158￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 159 1 We've seen hacking in politics before, but this 2 kind of, you know, mass theft of e-mail and then to 3 dump it all into, you know, the public sphere was 4 extraordinary and it was criminal. 5 So the question by now of whether this was 6 Russia and whether this might have something to do 7 with the other information that we'd received was, 8 you know, the immediate question, and I think this 9 is also -- by the time this memo was written Chris10 had already met with the FBI about the first memo.11 So he's -- if I can interpret a little bit here.12 In his mind this is already a criminal matter,13 there's already a potential national security14 matter here.15 I mean, this is basically about a month later16 and there's a lot of events that occurred in17 between. You know, after the first memo, you know,18 Chris said he was very concerned about whether this19 represented a national security threat and said he20 wanted to -- he said he thought we were obligated21 to tell someone in government, in our government22 about this information. He thought from his23 perspective there was an issue -- a security issue24 about whether a presidential candidate was being25 blackmailed. From my perspective there was a law￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 160 1 enforcement issue about whether there was an 2 illegal conspiracy to violate the campaign laws, 3 and then somewhere in this time the whole issue of 4 hacking has also surfaced. 5 So he proposed to -- he said we should tell 6 the FBI, it's a national security issue. I didn't 7 originally agree or disagree, I just put it off and 8 said I needed to think about it. Then he raised it 9 again with me. I don't remember the exact sequence10 of these events, but my recollection is that I11 questioned how we would do that because I don't12 know anyone there that I could report something13 like this to and be believed and I didn't really14 think it was necessarily appropriate for me to do15 that. In any event, he said don't worry about16 that, I know the perfect person, I have a contact17 there, they'll listen to me, they know who I am,18 I'll take care of it. I said okay. You know, I19 agreed, it's potentially a crime in progress. So,20 you know, if we can do that in the most appropriate21 way, I said it was okay for him to do that.22 Q. Okay. So let me just stop you there and23 let's just make sure we get the sequencing24 accurate.25 A. Sure.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. So after Mr. Steele had found out theinformation that he put in the very first of thesememos, the one dated June 20, 2016, he approachedyou about taking this information to specificallythe FBI, the Federal Bureau of Investigation? A. That's my recollection. Q. So to the best of your recollection, thatrequest or idea came directly from Mr. Steele, notanyone else? A. That's right. Q. And who was involved in discussions aboutwhether it was appropriate to take either the memoor the information in the memo to the FBI? A. It was Chris and me. I mean, that's theonly ones I remember, the two of us. The only onesI know of. Q. You said you had asked for some time tothink it over. What in particular did hearticulate to you was of significant nationalsecurity concern to indicate that it should betaken to the FBI? A. His concern, which is something thatcounterintelligence people deal with a lot, iswhether or not there was blackmail going on,whether a political candidate was being blackmailedPage 161￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 or had been compromised. And the whole problem of2 compromise of western businessmen and politicians3 by the Russians is an essential part of -- it's4 like disinformation, it's something they worry 5 about a lot and deal with a lot and are trained to 6 respond to. So, you know, a trained intelligence 7 officer can spot disinformation that you or I might 8 not recognize, certainly that was Chris's skill, 9 and he honed in on this issue of blackmail as being10 a significant national security issue.11 Chris is the professional and I'm not. So I12 didn't agree with that -- it wasn't that I13 disagreed with it. It was that I didn't feel14 qualified to be the arbitrar of whether this is a15 national security expert. He's the pro and I'm the16 ex-journalist.17 Q. In that regard when you say he's a18 professional and you're not, I take that to mean19 that he was the intelligence expert?20 A. He was -- yes, he was the national21 security guy. I know a lot about politics, I know22 a good bit about financial crime, but, you know, my23 specialty was journalism and his was security.24 Q. And with specific regard to the issue of25 blackmail, what was the -- what were the facts thatPage 162￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 he had gathered that made him concerned about the 2 possibility of blackmail and who did he think was 3 going to be blackmailed? 4 A. Well, the facts are -- beyond what's here 5 I don't have any additional facts. The alleged 6 incident that's described here is the one that he 7 was referring to. As I say, I don't have really 8 any additional information beyond this except 9 that -- I mean, it's probably in here somewhere10 actually, but it's well known in intelligence11 circles that the Russians have cameras in all the12 luxury hotel rooms and there are memoirs written13 about this by former Russian intelligence agents I14 could quote you. So the problem of kompromat and15 kompromating is just endemic to east-west16 intelligence work. So that's what I'm referring17 to. That's what he's referring to.18 Q. Got it. So that would be in the summary19 the kind of third dash point down where it20 mentions --21 A. Yes, that's right.22 Q. -- that FSB -- what is your understanding23 of who or what FSB is?24 A. It's a successor to the KGB. I mean,25 nominally it's the domestic intelligence agency onPage 163￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 164 1 the domestic side of what was the KGB. In practice 2 it's sort of the preeminent intelligence organ of 3 the Russian state, government. 4 Q. And do you recall when you -- when you and 5 Mr. Steele decided kind of that he could or should 6 take this to the FBI, approximately the time frame7 of that? 8 A. I believe it was sometime around the turn 9 of the month. It would have been in late June or10 at latest early July. That's my recollection.11 Q. And Mr. Steele was the one who was then12 responsible for doing the initial outreach to them13 and making that contact?14 A. Yes. Well, I mean, let's be clear, this15 was not considered by me to be part of the work16 that we were doing. This was -- to me this was17 like, you know, you're driving to work and you see18 something happen and you call 911, right. It19 wasn't part of the -- it wasn't like we were trying20 to figure out who should do it. He said he was21 professionally obligated to do it. Like if you're22 a lawyer and, you know, you find out about a crime,23 in a lot of countries you must report that. So it24 was like that. So I just said if that's your25 obligation, then you should fulfill your￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 165 1 obligation. 2 Q. And were you a part of those conversations 3 with -- that Mr. Steele had with whoever his 4 contact was at the FBI?5 A. No. 6 Q. Do you have any knowledge of when that 7 first conversation actually then took place? 8 A. Over the last several months that this has 9 become a public controversy I've learned the10 general date and I believe it was if first week of11 July, but I don't believe he told me -- if he told12 me the time, I don't remember when he told me.13 Q. And that information about that time, that14 first week of July, where does that come from?15 A. It comes from news accounts of these16 events and conversations between Chris and I and17 some of my -- presumably my business partners too.18 Generally speaking, we have, as you know, not been19 eager to discuss any of this in public and there's20 been a lot of speculation and guessing and stories,21 many of which are wrong. So when an incorrect22 story comes out we would, you know, talk about it.23 So, you know, in the course of those kinds of24 things I generally obtained a sense of when things25 occurred that I might otherwise not be able to￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

provide you. Q. And do you know who it is that Mr. Steelecontacted and talked with at the FBI? A. I did not know at the time. I believe Iknow now, but I don't have authoritativeinformation on that. I didn't -- yeah. I didn'tknow who it was in July. Q. And do you now know who that was? A. I think I know, but Chris never told me.I figured it out eventually based on other sourcesand other information, but that was not untilDecember or November. Q. December of -- November or December 2016? A. November, December 2016. It was after the election. Q. And what is your understanding from what you've been able to put together of who that would have been? A. My understanding of? Q. Of who Mr. Steele would have talked to at the FBI. A. I believe it was a , an official named24 .25 Q. And we had talked about that discussionPage 166￼￼￼￼￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 167 1 that you had with Mr. Steele about potentially 2 going to the FBI. You had indicated that it was 3 just the two of you having those conversations and 4 coming to that decision. Once the decision was 5 made, did you share that decision with anyone, that 6 he was going to go to the FBI with this 7 information? 8 A. I think we're not able to answer that. 9 MR. LEVY: He's going to decline to answer10 that question.11 BY MS. SAWYER:12 Q. Did you seek anyone else's approval for13 himtogoto the FBI?14 A. No.15 Q. Did anyone ever encourage you to ask him16 on to go to the FBI?17 A. No.18 Q. Did anyone discourage you from having him19 go to the FBI?20 A. No.21 Q. Do you know whether Mr. Steele when he had22 that first meeting, which you said occurred in the23 first week of July, do you know whether Mr. Steele24 actually gave the FBI this document that we've been25 talking about, the intelligence report 2016/080?￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

A. I don't know. Q. With regard to providing -- what was thegoal -- as you understood it, what was the purposeof the kind of goal in taking this to the FBI fromMr. Steele's perspective? MR. LEVY: Beyond what he's said already? MS. SAWYER: Yes.BY THE WITNESS: A. I mean, for him it was professionalobligations. I mean, for both of us it wascitizenship. You know, people report crimes allthe time. Q. So beyond reporting -- certainly if I'mmischaracterizing please let me know, but beyondreporting what he believed was an issue of nationalsecurity and a potential crime, I think you hadsaid kind of a potential crime in progress, do youknow whether he requested that the FBI open aninvestigation? A. I don't know that. I mean, all he told mein the immediate aftermath was that he filled himin. I can talk generally about the FBI and whathappens when you give them information because Iknow that from years of experience, but generally,you know, you don't ask them to do it. There's noPage 168￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 1691 ask. 2 Q. But you don't know what concrete steps 3 they may have taken once they got the information4 from him? 5 A. I do not. Of course we know now that 6 shortly thereafter they got a vice award on one of 7 the people who's dealt with in here. He's not 8 dealt with in this memo, but he's dealt with in the 9 later memos. I don't know there's any connection10 between these events. I do know in Director11 Comey's testimony he said -- I'm sorry. Maybe I'm12 skipping ahead. As far as I know, they didn't -- I13 don't know what they did.14 Q. So then with regard to Mr. Steele's15 ongoing work, I presume that his work then16 continued after you got this first memo because we17 have additional memos between June?18 A. Yes.19 Q. Was there a discussion about whether and20 when he would take information to the FBI?21 A. Not that I recall. After the initial memo22 he told me that he had briefed him. I don't23 remember anything specific about the issue arising24 again other than to say generally that as the25 summer progressed the situation with the hacking of￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 170 1 the Democrats and the efforts by the Russians to 2 influence the election and the possibility that the 3 Trump organization was, in fact, doing things to 4 curry favor with the Russians became more and more 5 serious as external developments occurred. 6 So, for instance, they changed the Republican 7 platform, which is addressed in here. Carter Page 8 shows up in Moscow and gives a speech. He's a 9 campaign advisor and he gives a speech about10 dropping sanctions. Trump continues to say11 mysterious things about what a great guy Putin is.12 So I vaguely recall that these external events13 prompted us to say I wonder what the FBI did,14 whoops, haven't heard from them. So that was15 basically the state of things through September16 Q. So do you know whether or not Mr. Steele17 did have any subsequent conversations with the FBI18 after that initial conversation in the first week19 of July 2016?20 A. Yes, I do. He did.21 Q. So can you explain the next incident where22 you know that Mr. Steele met with the FBI?23 A. Yes. I guess what I'd like to explain is24 what I knew at the time and what I know now. It25 was September and obviously the controversy was￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 171 1 really front and center now in the election. I 2 can't remember whether the intelligence community 3 had come out with their statement, but, you know, 4 there was a lot of concern in Washington and in the 5 U.S. about whether there was a Kremlin operation to 6 interfere with our election and there was a lot of 7 debate throughout this period about whether they 8 were trying to help Trump or just trying to cause 9 trouble. But there wasn't much debate that they10 were up to something.11 So, you know, I'm dealing with Chris on the12 underlying reporting and by this time my concern,13 you know, was -- I was very concerned because Chris14 had delivered a lot of information and by this time15 we had, you know, stood up a good bit of it.16 Various things he had written about in his memos17 corresponded quite closely with other events and I18 began, you know, to view his reporting in this case19 as, you know, really serious and really credible.20 So anyway, we were working on all of that and21 then he said, hey, I heard back from the FBI and22 they want me to come talk to them and they said23 they want everything I have, to which I said okay.24 He said he had to go to Rome, I said okay. He went25 to Rome. Then afterwards he came back and said,￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

you know, I gave them a full briefing. I'll add because I didn't consider this tobe -- you know, there was no objective herepolitically because you can't -- in an ordinaryelection I know from my decades of dealing withU.S. elections that you can't expect the governmentor the FBI to be of any use in a campaign becausethe DOJ has rules against law enforcement gettinginvolved in investigations in the middle of acampaign and this was obviously -- you know, thisobviously became a huge issue. Anyway, because it wasn't really part of theproject in my mind I didn't really ask a lot ofquestions about these meetings. I didn't ask whohe met with, I didn't ask, you know, much ofanything, but he did tell me that he gave -- Q. Before we get to that, which I do want tohear, I just want to get a sense of the chronology.A. Sure. Q. So when did that -- you had said the FBIthen came back and contacted Mr. Steele? A. That's my understanding. Q. When did that, to the best of yourknowledge, take place? A. Mid to late September.Page 172￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. So in that intervening time periodMr. Steele continues his research, he alsocontinues to provide you with memos?A. Yes. Q. And at no point in that time betweenJuly -- the first week of July when he first metwith the FBI and then mid to late September did yousuggest to him that he should go back to the FBI? A. Not that I recall. What I would -- what Ibelieve I may have said was have you heard anythingfrom the FBI because by then it was obvious therewas a crime in progress. So I just was curiouswhether he'd heard back. Q. And when you say it was obvious that therewas a crime in progress, what specifically are youreferencing? A. Espionage. They were hacking into thecomputers of Democrats and think tanks. That's acomputer crime. Q. So the thing that was apparent was Russiaor somebody had engaged in cyber intrusion andcomputer crimes?A. Yes. Q. So do you know whether or not Mr. Steelewas directed -- you said you did not direct him orPage 173￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

ask him to go back to the FBI -- whether anyoneelse either directly or indirectly asked him to goto the FBI after his July 5th -- A. To my knowledge, no one else told him toreport this. He may have conferred with hisbusiness associates, but I don't know. Q. And you said that meeting with the FBI,you said Mr. Steele said he had to go to Rome forthis meeting. Do you otherwise know who he metwith? A. This gets into the chronology of what Ilearned when. At some point I learned that he wasmeeting with the lead FBI guy from Rome. I don'tremember when he told me that. Q. And did you have a name associated withwho that was? A. Not at that time. Q. You said that he told you of the meetingwith the FBI in Rome in mid or late September, thathe "gave them a full briefing"? A. A debrief I think is what he probablysaid, they had debriefed him. I don't remember himarticulating the specifics of that. You know, myunderstanding was that they would have gotten intowho his sources were, how he knew certain things,Page 174￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 175 1 and, you know, other details based on their own 2 intelligence. Essentially what he told me was they 3 had other intelligence about this matter from an 4 internal Trump campaign source and that -- that 5 they -- my understanding was that they believed 6 Chris at this point -- that they believed Chris's 7 information might be credible because they had 8 other intelligence that indicated the same thing 9 and one of those pieces of intelligence was a human10 source from inside the Trump organization.11 Q. And did you have any understanding then or12 now as to who that human intelligence source from13 inside the Trump campaign might have been?14 MR. LEVY: He's going to decline to answer15 that question.16 MS. SAWYER: On what basis?17 MR. SIMPSON: Security.18 MR. LEVY: Security.19 BY THE WITNESS:20 A. We had been really careful -- I was really21 careful throughout this process to not ask a lot of22 specific sourcing questions. There are some things23 I know that I just don't feel comfortable sharing24 because obviously it's been in the news a lot25 lately that people who get in the way of the￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Russians tend to get hurt. MR. LEVY: And I would just add that thereare privileges and obligations that might beimplicated in the disclosure of any source relatedto this matter.BY MS. SAWYER: Q. Was this individual also a person who hadbeen a source for Mr. Steele, without identifyingwho that was?A. No. Q. So this was someone independent ofMr. Steele's sources who potentially hadinformation also on the same topics? A. Yes. I mean, I don't think thisimplicates any of the issues to say I think it wasa voluntary source, someone who was concerned aboutthe same concerns we had. MR. DAVIS: I'm having a hard time hearingyou. Please speak up.BY THE WITNESS: A. It was someone like us who decided to pickup the phone and report something. Q. And your understanding of this, does thatcome from Mr. Steele or from a different source? A. That comes from Chris, yes.Page 176￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. And when did he share that informationwith you? A. I don't remember exactly. Q. Do you think it was around the same timethat he had met with the FBI, so mid to lateSeptember of 2016? A. I think more likely early October. Q. Do you know whether when Mr. Steele metwith the FBI he provided them with the memos thathe would have had at that point in time, whichwould have been mid to late September of 2016? A. I don't know that. He didn't tell methat. He did say they asked him for -- they wantedto know everything he had, but whether that wouldinclude getting paper I don't know. Q. And did he indicate that he had cooperatedfully and given them whatever information he hadavailable? A. Yes. In the course of these, you know,discussions, you know, he indicated to me this wassomeone he had worked with previously who knew himand that they had a -- they worked together. Q. By that person you're referring to in Rome?A. Yes.Page 177￼￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 Q. Now, with regard to -- just to finish up2 on the interactions with FBI, do you know were3 there any additional interactions between4 Mr. Steele and the FBI? 5 A. There was some sort of interaction, I 6 think it was probably telephonic that occurred 7 after Director Comey sent his letter to Congress 8 reopening the investigation into Hillary Clinton's 9 e-mails. That episode, you know, obviously created10 some concern that the FBI was intervening in a11 political campaign in contravention of12 long-standing Justice Department regulation.13 So it made a lot of people, including us,14 concerned about what the heck was going on at the15 FBI. So, you know, we began getting questions from16 the press about, you know, whether they were also17 investigating Trump and, you know, we encouraged18 them to ask the FBI that question. You know, I19 think -- I'm not sure we've covered this fully,20 but, you know, we just encouraged them to ask the21 FBI that question.22 On October 31st the New York Times posed a23 story saying that the FBI is investigating Trump24 and found no connections to Russia and, you know,25 it was a real Halloween special.Page 178￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 179 Sometime thereafter the FBI -- I understandChris severed his relationship with the FBI out ofconcern that he didn't know what was happeninginside the FBI and there was a concern that the FBIwas being manipulated for political ends by theTrump people and that we didn't really understandwhat was going on. So he stopped dealing withthem. Q. Okay. So I do want to get to the timingon that. I know that I'm getting close to the endof my hour. Can I just ask you a general questionon the memos that we were talking about. I hadasked you specifically about the first one, if youhad in any way -- first of all, with regard to thepacket on whole, did you have any input orinvolvement in the drafting of these or input forthe research? A. No. Q. And did you edit any of them in any way? A. No. Q. So these were documents that you were justreceiving from Mr. Steele? A. Yes. I mean, the only qualifier I'd addis I'm sure I said things like Paul Manafort wasjust named campaign manager, what do you know about￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 180 1 him, that kind of thing. 2 Q. I do want to get into some more specifics 3 about kind of what steps and what items you may 4 also clarify, but I do want to make sure, if I 5 could have your indulgence, just that we -- well, 6 we can finish up the FBI part on our next hour 7 because it sounds like there's a little more to 8 finishing that. So our hour is up. If you'll just 9 give me a moment.10 Okay. So we'll go ahead and go off the11 record. It is 2:58.12 (A short break was had.)13 MR. DAVIS: We'll go back on the record.14 It's now 3:09.15 EXAMINATION16 BY MR. DAVIS:17 Q. Mr. Simpson, do you know Emin Agalarov,18 E-M-I-N, A-G-A-L-A-R-O-V?19 MR. LEVY: Personally or just does he know20 about him?21 MR. DAVIS: Personally.22 BY THE WITNESS:23 A. No.24 Q. Do you know Aras, A-R-A-S, Agalarov?25 A. No.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 Q. Has Fusion ever worked with either of2 them?3 A. No.4 Q. To the best of your knowledge, have5 either of them had any role in the Prevezon work?6 A. Not to my knowledge.7 Q. Do you know Rob Goldstone?8 A. No.9 Q. Has Fusion ever worked with him?10 A. No.11 Q. Paid him or been paid by him?12 A. No.13 Q. To the best of your knowledge, has14 Mr. Goldstone had any work in the Prevezon or15 Magnitsky work?16 A. Not to my knowledge.17 Q. When you had these dinners in June of 200618 with Ms. Veselnitskaya, who else attended those19 dinners?20 MR. FOSTER: 2016.21 MR. DAVIS: 2016. Excuse me.22 BY THE WITNESS:23 A. The Baker lawyers would have attended, did24 attend.25 Q. Was Rinat Akhmetshin there?Page 181￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

A. I specifically remember he was at thesecond dinner on I think it was the 10th. I don'tspecifically remember if he was at the otherdinner. I don't have many memory of the otherdinner. Q. Do you recall if he was at the courthearing on the 9th? A. I believe he was. I'm not certain of it.The other person would have been a translator atsome of these dinners. I can't remember whichones. Q. Were there any other individuals thereinvolved with HRAGI or Prevezon work beyond thepeople you've mentioned? MR. LEVY: When you say "there," you'retalking about now? MR. DAVIS: You're right. At the hearing.BY THE WITNESS: A. The hearing. Before you were asking aboutthe dinners, right?Q. I was. A. Now you're asking about the hearing. Ijust want to be clear. Well, it was a crowdedhearing and there may have been other peopleinvolved. I mean, I remember specifically prettyPage 182￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 183 1 much most of the Baker legal team was there, 2 Natalia was there, I believe she -- I believe 3 Anatoli was her translator for that. There was 4 some other people who I think were also from Baker 5 Hostetler who were there. Former Attorney General 6 Mukasey was arguing for Prevezon. So I just 7 remember that there were lawyers -- people who I 8 believed were lawyers who were there to watch the 9 argument and maybe had some connection to the case.10 There was another associate I think from New York11 who was there, usually came to some of the Court12 hearings. That's all I remember.13 Q. And the first dinner on the 8th were there14 any other attendees?15 A. I don't remember. I think John Moscow16 might have been there.17 Q. And the second dinner on the 10th, were18 there any other attendees beyond the ones you've19 already described?20 A. I don't recall. My wife.21 Q. You mentioned that information Fusion had22 gathered may have been passed on to the HRAGI23 people via Baker Hostetler or if they instructed24 you to that you would have. Did you have any25 expectation that that would reasonably result in￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 184 1 them influencing U.S. policy? 2 A. I can't say that I would have specifically 3 expected anything from that. I was acting -- 4 lawyers hire me to do research for them, the 5 research is their property or their client's 6 property, it's not mine. So if they want me to 7 provide it to somebody else, it's their 8 information. So I would -- it's a fairly 9 ministerial thing. I'm not sure I would have an10 expectation of any sort of specific result from11 that.12 Q. But you did understand HRAGI to be13 lobbying on the Hill?14 A. They were registered to lobby on the Hill.15 So I believe that's what they were doing, yeah.16 Q. And did you understand that your actions17 on behalf of Prevezon or Baker Hostetler would18 principally benefit the Russian government? Who19 did you believe the principal beneficiary to be?20 MR. LEVY: I'd like to note for the record21 that Patrick is smiling as he's asking the22 question. You can answer.23 MR. MUSE: He's trying to contain his24 laughter.25 BY THE WITNESS:￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 A. We did not believe that was being done on2 behalf of the Russian government.3 Q. What do you understand Prevezon's4 relationship, if any, to be with the Russian 5 government? 6 A. Prevezon was introduced to me as the 7 client and Denis Katsyv was the owner of Prevezon. 8 Generally speaking, when we take on a new case, you 9 know, from a respected law firm part of the, you10 know, discussion is who's the client, and, you11 know, Mark Cymrot said they've checked out Denis12 Katsyv and he has -- he's a legitimate businessman.13 He's got a real estate company, it's a successful14 company, and he has an explanation for how he makes15 his money and appears to be legit. To some extent16 whenever you enter a new case that's part of what17 you're being hired to determine is whether that18 initial due diligence stands up, but in any event,19 he was presented to me as a successful real estate20 investor.21 As I say, I worked with Baker Hostetler for a22 number of years and it's a conservative midwestern23 law firm with a lot of respected people in it, and24 part of the obligations of lawyers in this country25 and now in a lot of other countries is to determinePage 185￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

where their money comes from and who their clientsare and whether their clients are involved incriminal activity. I don't remember the exactspecifics of our discussions of these matters, butone of the issues was whether he's a legitimatebusinessman. Q. Did you ever receive a letter of inquiryfrom the Department of Justice regarding theapplicability of the Foreign Agent Registration Actto your work on the Prevezon case or Magnitskymatter? A. No, I have not. Q. Did you charge any fees to any otherentities or people besides Baker Hostetler for workon the Prevezon or Magnitsky matters? A. I don't think so, no. I specifically cantell you I wasn't compensated by this foundation oranybody else involved in any of the lobbying. Q. At the time of this June -- early Junetrip to New York had you already engaged Mr. Steeleto do work on Mr. Trump's involvement with Russia? A. I don't specifically remember. As Imentioned, the actual agreements are handled byother people on my staff. Q. Which employees and associates of FusionPage 186￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 worked on the project investigating then candidate2 Donald Trump?3 MR. LEVY: We can give you that information4 at the end of the interview. 5 MR. DAVIS: Why at the end of the interview? 6 MR. LEVY: I just want to make sure that 7 employees involved in this matter are protected. 8 We've had death threats come to the company. We'll 9 be happy to cooperate with the committee and give10 the names of those people. I just want to do it11 outside of this transcript, unless you're going to12 assure me the transcript is going to be kept13 confidential.14 MR. FOSTER: Let's go back to the previous15 question. What was the previous question?16 MR. DAVIS: Whether he'd already started17 working with Mr. Steele during the time of the --18 MR. FOSTER: During the time of the meetings19 in early June, right? And your answer was?20 MR. SIMPSON: I don't know.21 MR. FOSTER: Do you have -- you said you22 don't handle those issues at the company.23 MR. SIMPSON: That's right.24 MR. FOSTER: So your company does have25 records that would establish that fact?Page 187￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 188 MR. SIMPSON: We keep books and records. Weshould have records of agreements and things, yeah. MR. FOSTER: So did you not review any ofthose in preparation for today? MR. LEVY: What he reviewed is privileged. MR. FOSTER: Have you reviewed them -- I'mnot asking if you reviewed them with counsel. Haveyou reviewed them recently? MR. LEVY: If he reviewed anything to preparefor this interview it would have been at thedirection of counsel and attorney work product. MR. FOSTER: So you do or don't know whetheryou have such records that would identify thedate -- the precise dates of the engagements? MR. LEVY: We will -- MR. FOSTER: I'm just asking what he knows. MR. LEVY: I think he's told you. Go ahead. MR. SIMPSON: I'll just restate that we runa -- it's a reasonably well-run company, we keepbooks and records. So, you know, those kinds ofthings are kept in our corporate files.BY MR. DAVIS: Q. Did Baker Hostetler or Prevezon pay foryour travel to New York for the meetings in June of2016?￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 189 1 MR. LEVY: The meetings? 2 MR. DAVIS: The dinner after the hearing. 3 BY THE WITNESS: 4 A. The purpose of the trip was the hearing. 5 It was routine for me to attend hearings. So I 6 would bill them -- my office would bill them for my 7 train trips and hotels depending on whether there 8 was -- whether it was specifically for the Prevezon 9 case. I don't know if -- I don't know for a fact10 that we billed them.11 Q. Did you travel with any other members of12 the Prevezon team either to or from New York?13 A. I don't think so.14 Q. So I think you've already stated that Ed15 Baumgartner worked on both projects, on the16 Prevezon project and another Trump investigation.17 To the best of your knowledge, does Mr. Baumgartner18 know Rinat Akhmetshin?19 A. I don't know. I'd just like to clarify,20 you know, my recollection is that Ed worked -- the21 Prevezon thing wound down and I don't think I22 brought Ed on until it was either ending or had23 already ended.24 Q. Can you clarify the time frame for when it25 was winding down?￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MR. LEVY: Talk about what the "it" was whenyou say "it."BY THE WITNESS: A. The hearing was on June 9th, I guess wesaid, and that was the culmination of a longcontroversy over whether Browder was going to haveto testify and whether, you know, we had to bedisqualified and, you know, there was a wholeseries of media attacks on us during that periodfrom Browder. Then nothing happened after that andthat was, you know, sort of the peak of that. Itwas after that that a lot of the issues involvingRussia and the campaign started to heat up. Q. Was there any overlap between theemployees from Fusion who were working on the Trumpinvestigation and the Prevezon case? A. I think the primary employees did notoverlap, but I can't tell you that there was aChinese wall of separation. Various peoplespecialize in certain things and can contributead hoc to something. Q. And you worked on both, correct? A. Yes, I did. Q. You previously mentioned that Fusion hadhired subcontractors beyond Mr. Steele to work onPage 190￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

the Trump project. Was there any overlap of othersubcontractors between the Trump investigation andthe Prevezon work? A. Not to my recollection. Q. And had Fusion worked with Mr. Steeleprior to this project regarding Mr. Trump? A. Yes. Q. And had you previously paid him or Orbis? A. I believe so, yeah. Q. And had Fusion been paid by him or Orbisas well? A. Yes, I believe so. Q. And are you aware of any interactionsMr. Steele had with the FBI prior to his work onthe investigation of Mr. Trump and his associates? MR. MUSE: Could you repeat that? MR. DAVIS: Are you aware of any interactionswith Mr. Steele with the FBI prior to his work onthe investigation of Mr. Trump and his association?BY THE WITNESS: A. I was not at the time, but I am now. Q. Did you have reason to believe that in hisprior position within British intelligence he wouldhave interacted with the FBI? A. Yes, he's told me that.Page 191￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 Q. Do you believe that the FBI generally2 considers sources more credible if they have3 previously provided reliable information?4 A. That's my understanding.5 Q. Was Mr. Steele's reportedly successful6 history in working with the FBI a factor in7 deciding to hire Orbis for the Trump project?8 A. No. 9 Q. Do you know Christopher Burrows?10 A. Yes.11 Q. Do you know if he worked on the Trump-12 Russia project with Orbis?13 A. I do not.14 Q. Do you know Sir Andrew Wood?15 A. No.16 Q. Are you aware he's an associate of Orbis17 Business Intelligence?18 A. I am aware of that as of now. I didn't19 know it -- I don't know when I learned of it, but I20 didn't know it last year, much of last year.21 Q. Did Fusion ask Orbis to undertake other22 actions beyond preparing the memoranda containing23 the allegations regarding Mr. Trump and his24 associates?25 A. Not that I specifically -- I'm sorry. InPage 192￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

connection with that engagement? Q. In connection with that engagement. A. Not that I specifically recall. Q. Did you communicate with Mr. Steele otherthan through these memos? Did you have phone callsand e-mails with him? A. Mostly we spoke by phone. MR. FOSTER: You did also e-mail with him? MR. SIMPSON: Nothing -- I don't believe Ihad anything substantive. E-mail security is amajor problem. So, generally speaking, we wouldtry to communicate telephonically on an encryptedline. MR. FOSTER: Did you have another method ofcommunicating with him via text. MR. SIMPSON: I mean, we used encryptedmethods of communicating. Part of the securityconcern we have involve there's been a lot ofattempts to break into our systems. So I prefernot to get into a lot of that, but suffice to saywe use secured encrypted systems. MR. FOSTER: Regardless of the details of howyou did, do you retain copies of writtencommunications that you may have engaged with himthrough some other secure method?Page 193￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 194 1 MR. SIMPSON: Generally not. 2 MR. FOSTER: You have not retained? 3 MR. SIMPSON: Generally we use things that 4 can't be stolen because they no longer exist. 5 MR. FOSTER: Disappearing messages, auto 6 deleting messages? Is that correct? 7 MR. SIMPSON: That sort of thing, yes, that's8 correct. 9 MR. FOSTER: I just needed a verbal answer.10 MR. SIMPSON: Yeah. Sorry.11 BY MR. DAVIS:12 Q. You previously mentioned the relationship13 with Mr. Steele was more collaborative than a14 manager-employee and I think you referenced15 mentioning as an example Paul Manafort's been named16 campaign chairman, what do you know about him. Did17 you collaborate with Mr. Steele on the content of18 the memos even if he did the drafting?19 A. No, generally speaking. I was managing a20 much bigger project and he's a reliable provider.21 So I did very little tasking.22 Q. You mentioned other subcontractors were23 focusing on other regions in which the Trump24 organization has business. Were those other25 subcontractors retained until the election or how￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

long did their engagements last? A. It was ad hoc. So as things came we saidcan we find someone in Latin America, give them anassignment, they'd complete the assignment. Ifthere's no more to do, stop. So it's hard togeneralize. Q. One point I'd like to clarify fromMs. Sawyer's questioning. I believe you said thatMr. Steele had told you that the FBI had a sourcefrom inside the Trump organization and I believeshe referred to a source from inside the Trumpcampaign. Do you know which is the accurate -- MR. LEVY: He's not going to get into thedetails of that source. MR. DAVIS: I'm not asking for any particulardetails. It was characterized differently by youand by counsel. I just wanted to make sure.BY THE WITNESS: A. I don't know. MR. FOSTER: So you don't know whether it wasthe organization or the campaign, in other words? MR. SIMPSON: That's correct. MR. FOSTER: Meaning the business versus thecampaign.BY MR. DAVIS:Page 195￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. And did Mr. Steele tell you that the FBIhad relayed this information to him? A. He didn't specifically say that. Q. I'm going to have you take a look at oneof the filings -- MR. FOSTER: I thought you said earlier thathe did say the FBI told him. MR. SIMPSON: I think I was saying we did nothave the detailed conversations where he woulddebrief me on his discussions with the FBI. Hewould say very generic things like I saw them, theyasked me a lot of questions, sounds like they haveanother source or they have another source. Hewouldn't put words in their mouth. (Exhibit 4 was marked for identification.)BY MR. DAVIS: Q. I'm going to have you take a look at oneof the filings by Mr. Steele's attorneys in thelawsuit against him and Orbis in the UnitedKingdom. This will be Exhibit 4. If you couldplease turn to page 2 and read paragraph No. 8.That paragraph states "At all material times Fusionwas subject to an obligation not to disclose tothird parties confidential intelligence materialPage 196￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

provided to it by the Defendants in the course ofthat working relationship without the agreement ofthe Defendants." Is that a correct description ofyour understanding of how the material was to betreated? MR. MUSE: There's also a context to that whothe Defendants are in other such matters. MR. DAVIS: Sure. The Defendants are OrbisBusiness Intelligence Limited and ChristopherSteele.BY THE WITNESS: A. What's the question? Q. Is that an accurate description of whatyou understood the obligations to be with thatmaterial? A. I mean, that's hard for me to answer.There's a mutual expectation of confidentiality,and if that's what you read that as saying, thenyes, there's a mutual expectation ofconfidentiality. Q. Was that expectation established bycontract? MR. LEVY: We're not going to talk aboutcontracts with clients.BY MR. DAVIS:Page 197￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Q. Was it established by practice? A. I guess I'll just reiterate we doconfidential work together and we treat all mattersas confidential. He's pretty good at sticking tothat and so am I. Q. Was any of the information included in thememoranda Orbis prepared during the Trumpinvestigation not considered "confidentialintelligence" under this understanding such thatFusion was not required to obtain Orbis'spermission in order to disclose it? A. I don't really understand the question. Q. I'm saying if the understanding is thatyou weren't to disclose confidential intelligencematerial, were the memos confidential intelligencematerial, the dossier memos? A. They're confidential, yes. MR. MUSE: Hold on one second. Here's themischief that's created by that. Someone else issending this and you're asking what they mean.There may be direct answers to those questions ifyou ask direct questions, but to do it in the frameof reference of someone else putting forth a pieceof evidence, which this is, it inevitably createsconfusion. The reference to the document addsPage 198￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 199 nothing to his knowledge. It's just simply a pointof reference by you, but it doesn't add anything towhat he might be saying. So I think the better wayto get at it is simply to ask direct questions. MR. DAVIS: There are two parties to this, atleast, and we've got one's description. I'd liketo know if he agrees with that description. MR. MUSE: But even within what do they meanby this is the question. I mean, what do they meanby this sort of paragraph. You're asking him foran interpretation. He can answer questions aboutthe relationship. MR. DAVIS: I'm asking him to give aninterpretation of their agreement in terms of whathe did. MR. MUSE: And therein lies the problem. MR. DAVIS: But if it's an agreement to whichhe's a party, there's a basis for thatunderstanding. MR. MUSE: I don't think that's the way therule works. MR. FOSTER: Well, I think the biggermischief from my point of view is the fact thatwe're trying to get an understanding of what thecontractual relationship was. You're telling us￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼Page 200 1 you're not going to provide us with details about 2 that contractual relationship, you're not going to 3 provide us with copies of any nondisclosure 4 agreements, contracts we've asked for and we don't 5 have. So we're asking him for his understanding of 6 what obligations he had. 7 MR. LEVY: And that's outside the scope of 8 this interview. Go ahead. 9 MS. SAWYER: Can I in general ask that you10 guys all speak up a little bit because we're right11 under the blower.12 MR. LEVY: Will do.13 MR. FOSTER: The record will reflect we are14 not raising our voices.15 To be clear, you're instructing him not to16 answer that question because you think it's outside17 the scope of what he agreed to come here to talk18 about voluntarily?19 MR. LEVY: That's not what I said. You had20 made a comment about contracts, and I just wanted21 to make sure that obviously the Chair and the22 Ranking Member have agreed those questions are not23 part of the scope of this interview. That said,24 I've now forgotten what the pending question was.25 So if Patrick wants to restate it he can and we can1-800-FOR-DEPOwww.aldersonreporting.com

Glenn SimpsonAugust 22, 2017Washington, DC￼Page 201 1 evaluate it. 2 MR. DAVIS: Sure. In general we're asking 3 questions about distribution of the material within 4 the dossier which was the scope of the agreement. 5 If you look at page 4 of that same exhibit, 6 paragraph 30, Steele's attorneys state "The 7 Defendants" -- and again, that's Orbis Business 8 Intelligence and Christopher Steele -- "did not 9 however provide any of the pre-election memoranda10 to any of the media or journalists, nor did they11 authorize anyone to do so, nor did they provide the12 confidential December memorandum to media13 organizations or journalists, nor did they14 authorize anyone to do so."15 To the best of your knowledge, did Orbis ever16 authorize Fusion to make any disclosures of the17 memoranda to the media?18 MR. LEVY: Just before we get into this19 question, this paragraph began with a sentence you20 did not read and it says "In the first sentence of21 subparagraph 8.2.5 as noted." I don't know what22 they're referring to. Maybe you do. Can you show23 us that?24 MR. DAVIS: I don't have that with me at the25 moment, but I'll see if we can find it. Regardless,1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 202 did Orbis ever authorize you to share the memorandawith the media?BY THE WITNESS: A. I'm not sure I can answer this in -- I'mnot sure I know the answer to this. MR. LEVY: If you don't know, then... MR. SIMPSON: It's a little confusing. MR. FOSTER: You don't know whether or notOrbis or Mr. Steele authorized you to distributethe memos to the media? MR. SIMPSON: I think what I would like tosay is that we had discussions about, you know,information as opposed to memos and, you know, atvarious times in talking to reporters about theTrump-Russia connection, you know, things -- thosediscussions would be informed by what's in thememos. MR. FOSTER: So are you saying that you mayhave provided information from the memos to themedia without discussing whether or not -- withoutgetting permission specifically From Mr. Steele orOrbis? MR. SIMPSON: What I'm saying is we discussedthat. No. I'm saying we discussed generally thewisdom of answering questions from reporters about￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 203 1 different matters, what we could say and what we 2 couldn't say. 3 MR. FOSTER: And in those discussions did he 4 ever authorize you to discuss the information 5 contained in the memoranda with the media? 6 MR. SIMPSON: As I've stated before, this is 7 not a master-servant relationship. We worked 8 together. Sometimes he's working for my clients, 9 sometimes I'm working for his. So we might jointly10 make a decision, but it's not a sort of can I do11 this, yes you can do that kind of relationship. So12 if they -- so I hope that's responsive.13 MR. FOSTER: So did you ever share either the14 memos or the content of the memos with the media15 independently of him without having discussed it16 with him?17 MR. SIMPSON: I think what I said was I had18 spoken with reporters over the course of the summer19 and through the fall about the investigations by20 the government and the controversy over connections21 between -- alleged connections between the Trump22 campaign and the Russians. Some of what we23 discussed was informed by Chris's reporting. So24 whether that was -- I don't think there's any sense25 that that was an unauthorized thing to do.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MR. DAVIS: On page 5 -- MR. FOSTER: Is it something that youdiscussed with him that you were doing? MR. SIMPSON: We would discuss inquiries thatwe had received from reporters, yes. MR. FOSTER: And that you were answering? MR. SIMPSON: To the best of our ability. Imean, we obviously didn't tell people about theexistence of these things for a long time.BY MR. DAVIS: Q. On page 5 of that same exhibit, paragraph32 there's a portion of the sentence -- and I'lljust read this for background before we move on toanother segment. I think this is relevant forcontext. There's a portion here in which Steele'sattorneys state that he gave -- that the Defendantsgave "Off-the-record briefings to a small number ofjournalists about the pre-election memoranda inlate summer/autumn 2016." I'd like to provideExhibit 5 which is the second filing byMr. Steele's attorneys. MS. SAWYER: Patrick, you've represented thisone as the second filing. Are we sure these are -- MR. DAVIS: Second for the purpose of thisinterview, second one we're referencing.Page 204￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MS. SAWYER: Were these documents that wererequested or obtained from a third party in thecourse of the investigation? MR. DAVIS: These were documents that werepublished in the media. I believe the second onewas published by McClatchy. MS. SAWYER: And what about the first? MR. DAVIS: That was the one published by theWashington Times. (Exhibit 5 was marked for identification.)BY MR. DAVIS: Q. So with the second one on page 8 ofExhibit 5, under the response to 18 Steele'sattorneys state "The journalists initially briefedat the end of September 2016 by the secondDefendant and Fusion at Fusion's instruction werefrom the New York Times, the Washington Post, YahooNews, the New Yorker, and CNN. The secondDefendant" -- that would be Mr. Steele --"subsequently participated in further meetings atFusion's instruction with Fusion and the New YorkTimes, the Washington Post, and Yahoo News whichtook place in mid-October 2016. In each of thosecases the briefing was conducted verbally inPage 205￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 206 1 person. In addition, and again at Fusion's 2 instruction, in late October 2016 the second 3 Defendant briefed the journalist from Mother Jones 4 by Skype. No copies of the pre-election memoranda 5 were ever shown or provided to any journalist by or 6 with the authorization of the Defendants. The 7 briefings involved the disclosure of limited 8 intelligence regarding indications of Russian 9 interference in the U.S. election process and the10 possible coordination of members of Trump's11 campaign team and Russian government officials."12 To the best of your knowledge, is that a full13 and accurate account of all the news organizations14 with which Fusion and Mr. Steele shared information15 from the memoranda.16 A. I'd say it's largely right.17 Q. Are there any that have been omitted?18 A. Maybe, yeah.19 MR. LEVY: Just say what you know or recall.20 BY THE WITNESS:21 A. Yeah. I think there's at least one thing22 misidentified. There might have been another. I23 can't specifically think of it, but I think this is24 incomplete, that maybe one of the broadcast25 networks is misidentified. I just don't have a￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 207tally of this. It's mostly right. Q. By broadcast network I assume you mean CNNis incorrect, it was a different network? A. I think so. Q. Do you recall which network it was? A. I think it was ABC. Q. Did you attend these meetings withMr. Steele? A. Yeah. Yes. Q. Did any other Fusion associates attend? A. Possibly, yes. Q. Can you identify them? MR. LEVY: We can give that to youafterwards.BY MR. DAVIS: Q. Do you recall the specific dates of thesemeetings?A. No. Q. I believe the filing says end of September2016. Does that comport with your recollection?A. Yes. Q. Was this, as far as you know, before orafter Mr. Steele had had his second meeting withthe FBI? A. I don't remember. Sorry.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 208 Q. Did Mr. Steele ever indicate to youwhether the FBI had asked him not to speak with themedia? A. I remember Chris saying at some point thatthey were upset with media coverage of some of theissues that he had discussed with him. Q. Sorry. I didn't hear. A. He never said they told him he couldn'ttalk to them. Q. Do you recall which journalists you spoketo at each of these organizations and whatinformation from the memoranda was revealed toeach? A. I remember some of them and I remembersome of the names, yeah, some of the people Italked to and some of these discussions. Q. Can you tell us what those were? MR. LEVY: The answer to that question goesto confidential conversations that's been declinedto answer. MR. FOSTER: Sorry. Confidential what? MR. LEVY: The answer to that question mightimplicate privilege and other obligations we'vealready set forth and he's not going to answer thequestion.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MR. FOSTER: What's the privilege?MR. LEVY: First amendment, confidentiality.MR. FOSTER: Confidentiality agreement,contractual obligation, is that what you're talkingabout? MR. LEVY: No. Just talking to confidentialsources, First Amendment issue. We can discuss itlater after the interview.BY MR. DAVIS: Q. Mr. Steele's filing indicates that thesemeetings occurred at Fusion's instruction. Is thatcorrect, did you initiate these meetings andinstruct Mr. Steele to participate in them? A. I'd just reiterate the nature of ourrelationship was that we would -- I might proposesomething and he might agree to do it, but it wasnot a -- it was not a military style relationshipwhere I gave the orders and he carried them out. Q. Was part of the purpose of yourinvestigation to share information withjournalists? A. I think that's a fair statement. To theextent -- I mean, I'm sorry. Could you be clear.You mean the project overall? Q. Yes, investigating Mr. Trump and hisPage 209￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

associates. A. As I said earlier, in any project, andthat would include this one, the objective is togather relevant information, and some of thatinformation was gathered for other purposes andsome of it was gathered for the possibility that itmight be useful to the press. Q. Did your client instruct you to have thesemeetings? MR. LEVY: The answer to that question mightimplicate privilege or obligations that we've setforth.BY MR. DAVIS: Q. Do you have any reason to believe thatMr. Steele passed any information on to journalistswithout Fusion? A. Without me -- you mean without meparticipating, without me authorizing it? Can yoube more specific? Q. Sure. Let's start without youparticipating. The filing references meetings thatboth you and Fusion jointly had with journalists.Do you believe he had any meetings with journalistswithout you present? MR. LEVY: Without Mr. Simpson physicallyPage 210￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

present? MR. DAVIS: For physical meetings or viaSkype, without him aware of them contemporaneously.BY THE WITNESS: A. That's a difficult question to answerbecause I don't know what I don't know, but I don'thave any reason to believe that he did anythingthat I didn't authorize or approve. Q. Jason may have already touched on this,but did Fusion disclose hard copies of thememoranda to any journalists? MR. LEVY: The answer to that question mightimplicate privilege or obligations. So he's goingto decline to answer that question. MR. FOSTER: Doesn't the filing say that theydid not? MR. LEVY: While our letter to the committeehas said that neither Mr. Simpson nor Fusion GPSprovided the dossier to BuzzFeed, Mr. Simpson'sgoing to decline to answer your questionrespectfully. He's given you a lot of informationtoday. He's not going to answer that question.BY MR. DAVIS: Q. Still with Exhibit 5 on page 2, theresponses to 4 and 6. Here the attorneys for OrbisPage 211￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 and Mr. Steele -- 2 MR. LEVY: Where are you again? 3 BY MR. DAVIS: 4 Q. Page 2, the response to 4 and to 6. Here 5 the attorneys for Orbis and Mr. Steele state "The 6 duty not to disclose intelligence to third parties 7 without the prior agreement of the Defendants" -- 8 again, that's Orbis and Mr. Steele -- "do not 9 extend to disclosure by Fusion to its clients,10 although the Defendants understand that copies of11 the memoranda were not disclosed by Fusion."12 A. Where are you? You're on page 2 -- okay.13 I see it now.14 Q. -- "do not extend to disclosure by Fusion15 to its clients, although the Defendants understand16 that copies of the memoranda were not disclosed by17 Fusion to its clients."18 Further down on that same page in response to19 a question about whether Fusion's clients, insofar20 as disclosure to them, was permitted, could21 themselves disclose the intelligence from Orbis,22 the filing responds "Defendants understood that the23 arrangement between Fusion and its clients was that24 intelligence would not be disclosed."25 Is that a correct statement of thePage 212￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 213 1 relationship between you and the client, did Fusion 2 not disclose the memoranda or information contained 3 there in to its clients? 4 MR. LEVY: He's not going to get into 5 discussion with the client because of privileges 6 and obligations that might be implicated by the 7 answer to that question. 8 BY MR. DAVIS: 9 Q. Do you believe this filing is accurate in10 those paragraphs?11 MR. LEVY: Again, to comment on that he would12 have to talk about client communications that are13 privileged and might implicate privilege or14 obligation were he to answer your question.15 BY MR. DAVIS:16 Q. Mr. Simpson, do you believe that any17 confidentiality obligations regarding the memos did18 not extend to law enforcement and intelligence19 services?20 A. Yes. I mean, I -- well, in general I21 think that in the course of any sort of22 confidential business lawyers or other23 professionals engage in if they come across24 information about a possible terrorist attack or a25 mafia operation they should report it, yes, and￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

that that is, in fact, not covered by ordinaryconfidentiality. Q. Was Fusion aware of the reports that theFBI considered -- let me rephrase. Was Fusionaware that the FBI considered paying Mr. Steele toinvestigate Mr. Trump and his associates? A. When? Q. At any time. MR. LEVY: When you say "paying," what do youmean by that? MR. DAVIS: Providing money. MR. LEVY: For a fee? Are you talking aboutreimbursements? MR. DAVIS: Fees or reimbursements in thiscontext.BY THE WITNESS: A. We've learned that. We know that now. Infact, it was -- MR. LEVY: Learned what?BY THE WITNESS: A. Well, we learned -- sometime after theelection we learned that Chris had discussedworking for the FBI on these matters after theelection and that that didn't happen. Q. Did Mr. Steele discuss that with you atPage 214￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

the time? A. He didn't discuss it -- I don't rememberexactly when he mentioned this to me, but hementioned to me at some point I think after theelection that he had discussed this with them. MR. FOSTER: So prior to news reports to thateffect? In other words, you learned it from himnot from the news; is that right? MR. LEVY: Wait. You asked two differentquestions. I'm trying to figure out which one youwant him to answer. MR. FOSTER: The last one. MR. LEVY: What was the last one? MR. FOSTER: You learned it from the news andnot from him? Are you saying you learned it fromhim? MR. LEVY: Learned what from him? MR. FOSTER: That he discussed with the FBIhaving the FBI pay Mr. Steele. MR. SIMPSON: I don't remember. MR. LEVY: The witness is yawning. Let'stake a break. MR. MUSE: We will attribute that to fatigueas opposed to the questions. MR. FOSTER: Let's go off the record. It isPage 215￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

3:55.It's now 4:05. We'll continue with the questions.BY MR. DAVIS: Q. Mr. Simpson, did anyone from Fusion evercommunicate with the FBI regarding information inthe memoranda or other allegations regardingMr. Trump and his associates? A. From Fusion, did anyone from Fusioncommunicate with the FBI? No, no one from Fusionever spoke with the FBI, to the best of myknowledge. Q. Did you ever exchange any e-mails withthem? (A short break was had.)MR. DAVIS: We'll go back on the record. A. We did not communicate with them by e-maileither. Q. Do you know any current or former FBIpersonnel? MR. LEVY: As a general matter? MR. DAVIS: Yeah, as a general matter.BY THE WITNESS: A. As a general matter I'm sure I do. I knowcurrent and former law enforcement officials. I goto a lot of crime conferences and things likePage 216￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017

Page 217that. Q. Were any of them consulted as part of thisinvestigation? A. Not to my recollection. Q. Was the amount of Fusion's compensation inthe Trump investigation dependent on the FBIinitiating an investigation of Mr. Trump or hisassociates?A. No. Q. Was the amount of Orbis's compensationdependent on the FBI initiating an investigation ofMr. Trump and his associates?A. No. Q. Other than Senator McCain, who we'lldiscuss later, did Fusion or Orbis disclose any ofthe memoranda information contained therein orrelated information from Mr. Steele with anyelected officials or staff in Congress? A. I don't recall having done so, no. Q. If we could turn briefly back to Exhibits4 and 5. I just want to reference two things. MR. LEVY: I also want to clarify in thepremise of that question there were factualassertions made that may or may not be true towhich the witness did not respond.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 MR. DAVIS: Sure. Understood. To be clear,2 we obviously were not referencing any disclosures3 to this committee as part of the committee's4 inquiry. 5 BY MR. DAVIS: 6 Q. So on Exhibit 4, page 3, paragraph 21A, 7 Mr. Steele's attorneys state that the post-election 8 dossier memoranda was provided to a senior United 9 Kingdom government national security official10 acting in his official capacity. In Exhibit 5 on11 page 2 -- I'm sorry -- page 5, the response to 1312 similarly references disclosing that memoranda to13 the UK national security official.14 Mr. Simpson, to the best of your knowledge,15 were the memoranda or information contained therein16 disclosed to foreign governments?17 A. I have no knowledge of this beyond what18 you're showing me. I can tell you about, you know,19 what I know about Chris's encounter with David20 Kramer and how all that came about. If Chris21 specifically said something to me about showing22 this to one of his government officials I don't23 remember it. So...24 MR. LEVY: Why don't you walk them through.25 BY THE WITNESS:Page 218￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 219 1 A. If you want to know the rest of the story, 2 I'm happy to walk you through it. 3 Q. Sure, we can do that. 4 A. So after the election obviously we were as 5 surprised as everyone else and Chris and I were 6 mutually concerned about whether the United States 7 had just elected someone who was compromised by a 8 hostile foreign power, more in my case whether the 9 election had been tainted by an intervention by the10 Russian intelligence services, and we were, you11 know, unsure what to do. Initially we didn't do12 anything other than to discuss our concerns, but we13 were gravely concerned.14 At some point a few weeks after the election15 Chris called me and said that he had received an16 inquiry from David Kramer, who was a long-time17 advisor to Senator McCain, and that according to --18 Kramer told Chris that he had run into Sir Andrew19 Wood at a security conference in Halifax,20 Nova Scotia and that Kramer was accompanying21 Senator McCain to this conference and that the22 three of them had had an unscheduled or unplanned23 encounter where the issue of this research was24 discussed and the essence of it, I guess, was25 conveyed to Senator McCain and to David Kramer from￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 220 1 Andrew Wood. I don't remember whether Andrew 2 Wood's name was specifically given to me by 3 Christopher Steele at that time. It was later 4 given to me. It later became an accepted fact that 5 Chris had mentioned him to me. I believe he 6 probably mentioned it. 7 But anyway, he did say someone that he worked 8 with in the past who was a former UK government 9 official with experience in Russia had had this10 conversation with David Kramer and John McCain and11 that Senator McCain had followed up on it as to12 what more there was to know about these13 allegations, this information.14 So Chris asked me do you know David Kramer,15 and I said yes, I've known David Kramer for a long16 time. David Kramer is part of a small group of17 people that I'm sort of loosely affiliated with.18 We've all worked on Russia and are very concerned19 about kleptocracy and human rights and the police20 state that Russia has become, in particular the21 efforts of the Russians to corrupt and mess with22 our political system. So we shared this concern23 going back to when I was at the Wall Street Journal24 and that's how I met David. He was working at the25 State Department as assistant secretary for human￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 221 1 rights, and I was reporting on human rights and 2 corruption in Russia. 3 So I told Chris he's legit. David is someone 4 I've known for a long time and he knows a lot about 5 these issues and he's very concerned about Putin 6 and the Kremlin and the rise of the new Russia and 7 criminality and kleptocracy. So he said, well, can 8 we trust him? And I said yes, I think we can trust 9 him. He says he wants information to give to10 Senator McCain so that Senator McCain can ask11 questions about it at the FBI, with the leadership12 of the FBI. That was essentially -- all we sort of13 wanted was for the government to do its job and we14 were concerned about whether the information that15 we provided previously had ever, you know, risen to16 the leadership level of the FBI. We simply just17 didn't know. It was our belief that Director Comey18 if he was aware -- if he was made aware of this19 information would treat it seriously.20 Again, at this time, you know, while we21 believed that we had very credible reporting here,22 you know, what we really -- we just wanted people23 in official positions to ascertain whether it was24 accurate or not. You know, we just felt that was25 our obligation. So I said to Chris I think we can￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 222trust him, and he said okay. Well, he was here, Imet with him, and I told him what happened. Nowhe's back in Washington and, you know, I'm going tohand him to you. I don't remember whether I called David orDavid called me, I just don't remember, but we gotin touch and he, you know, asked me -- we met. Q. And after you met how did he -- did youprovide the memoranda to -- MR. LEVY: Sorry. Finish your question.BY MR. DAVIS: Q. -- did you provide the memoranda to him? MR. LEVY: The answer to that question mightimplicate privilege and other obligations. So he'sgoing to decline to answer the question.BY MR. DAVIS: Q. Did Mr. Steele represent to you that Orbisor Mr. Wood had initiated this contact withMr. Kramer and Mr. McCain to share the dossierinformation? A. Well, that has two parts on that question.I think I can answer the first part which I thinkanswers the second. Anyway, he did not describethis as having been initiated by Orbis. Hedescribed this as a chance encounter at a security￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

conference where, you know, someone who had someknowledge of these matters shared it with SenatorMcCain and David Kramer and that caused DavidKramer to follow up with Chris and that it waspassive. In other words, it was initiated byMr. Kramer. Q. Did Mr. Steele describe anyone else beinginvolved at the Halifax international securityconference in this discussion? A. Not that I can recall. Q. According to the official attendee listfor that conference, Mr. Akhmetshin was also there.To the best of your knowledge, was he involved inany capacity in the effort to discuss the dossierinformation with Mr. Kramer and Mr. McCain? A. That's the first time I've received thatinformation. So I don't have any knowledge. Q. And you haven't spoken with Mr. Akhmetshinabout that, I assume?A. No. Q. In addition to the disclosures we havealready discussed, to whom did Fusion GPS providethe memoranda, information contained therein, orrelated information from Orbis? MR. LEVY: Beyond what you've discussed?Page 223￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

MR. DAVIS: Anyone we've left out. MR. LEVY: The answer to that might implicateprivilege or other obligations. So he's going todecline to answer the question.BY MR. DAVIS: Q. To the extent there's any portion of theanswer to that question that would not implicatethose privileges, I would ask that you revealthose. A. I'm not sure I see how I could answer thatquestion without getting into privileged areas. MR. FOSTER: Again, what privilege? MR. LEVY: We can discuss it at the end.It's a voluntary interview. He's declining toanswer that.BY MR. DAVIS: Q. Did any Fusion employees communicate withany foreign governments or foreign intelligenceagencies about the memoranda or the informationcontained therein? A. I don't believe so, certainly notknowingly. Q. Did you and Mr. Steele ever discuss anycommunications he had with foreign governmentofficials about the information in the memoranda?Page 224￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 225 1 A. It would be difficult -- nothing specific 2 that I recall. There are parts of the memos that 3 talk about information that foreign government 4 officials provided in the course of their research, 5 but beyond what's in the memos I don't really have 6 any recollection. 7 Q. Do you know who paid for Mr. Steele's trip 8 to Rome to meet with the FBI?9 A. I have read recently that--Ithinkina10 letter from Senator Grassley that the FBI11 reimbursed the expense, but to be clear, I mean,12 that's it. He was, to my knowledge, not been13 compensated for that work or any other work during14 this time.15 MR. FOSTER: I'm sorry. You're saying that16 Fusion did not pay for the trip?17 MR. LEVY: Go ahead and answer the question.18 MR. SIMPSON: I don't think we did. I have19 no information that we paid for it. Again, this20 sort of emphasizes, you know, the point I was21 making earlier which was this was something that I22 considered to be something that Chris took on on23 his own based on his professional obligations and24 not something that was part of my project. So it25 makes sense to me that he was reimbursed by them,￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

not us.BY MR. DAVIS: Q. To clarify, you were saying hisinteractions with the FBI were not part of yourproject? A. They obviously grew out of the project,but as he explained it to me, you know, when youlearn things in your daily life that raise nationalsecurity considerations you're obligated to reportthem. So that wouldn't have anything to do with myclient's goals or project. Q. But in your briefings with journalists youdid reference his interactions -- Mr. Steele'sinteractions with the FBI, correct? A. At some point that occurred, but I don'tbelieve it occurred until very late in theprocess. Q. Can you estimate when in the process? A. It was probably the last few days beforethe election or immediately thereafter. Q. So the meetings in September that youreferenced, you didn't reveal Mr. Steele passing oninformation to the FBI? MR. LEVY: Can you repeat the question.Sorry.Page 226￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 MR. DAVIS: So in your meetings with 2 journalists in September you didn't reference 3 Mr. Steele's interactions with the FBI or passing 4 on of information to them? 5 BY THE WITNESS: 6 A. I don't recall. 7 MR. DAVIS: I think my hour is up. 8 MR. FOSTER: Off the record at 4:21. 9 (A short break was had.)10 MS. SAWYER: We'll go back on the record.11 It's 4:30.12 EXAMINATION13 BY MS. SAWYER:14 Q. I wanted to return to our conversation15 about interactions that Mr. Steele had with the16 FBI. We had been talking about a second time he17 met in Rome. Besides that meeting and the first18 meeting in early July, are you aware of any other19 meetings or conversations that Mr. Steele had with20 the FBI?21 A. I think I was just recounting that he22 vaguely said that he had broken off with them over23 this concern that we didn't really know what was24 going on. I'm sorry to be vague, but we just25 didn't understand what was going on and he said hePage 227￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 228 1 had broken off with them. 2 Q. When you say "we" did not understand what 3 was going on, who are you referring to as the "we"? 4 A. Chris and I, mostly just the two of us. 5 There was a lot of public controversy over the 6 conduct of the FBI. I remember discussing it with 7 many people, but this conversation was between the8 two of us. 9 Q. And what was the time frame of when Steele10 said he had broken off with the FBI?11 A. I can -- I don't know exactly, but it12 would have been between October 31st and election13 day.14 MS. QUINT: October 31st was when you said15 there was an article --16 MR. SIMPSON: In the New York Times. There17 was an article in the New York Times on18 October 31st that created concern about what was19 going on at the FBI.20 MS. QUINT: Because it wasn't consistent with21 your understanding of the investigation?22 MR. SIMPSON: Exactly.23 BY MS. SAWYER:24 Q. And I think, just to be clear, this was an25 article you had talked about that both revealed￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 229 1 that Director Comey had alerted Congress to 2 something about the Clinton e-mail investigation? 3 A. No. That happened a few days previous. I 4 don't know the exact date that he sent the letter 5 to Congress, but this was an article specifically 6 about -- it was disclosing the existence of an FBI 7 investigation of Trump's ties to Russia, which, to 8 my recollection, was the first time that anyone 9 reported that the FBI was looking at whether the10 Trump campaign had ties to the Kremlin but at the11 same time saying that they had investigated this12 and not found anything, which threw cold water on13 the whole question through the election.14 Q. And was that -- just to tie it together15 when you were talking previously, was that in16 connection with your conversation with journalists17 where you directed them to ask the FBI as to18 whether there was an investigation going on?19 A. I'm not going to get into specific news20 organizations or reporters or stories, but I would21 restate that this was during the period when we22 were encouraging the media to ask questions about23 whether the FBI was, in fact, investigating these24 matters.25 I'll add that, you know, a lot of what we￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 were talking to the media about were things in the 2 public record, specifically Carter Page, Paul 3 Manafort had resigned over allegations of illicit 4 relationships with Russian oligarchs and Ukrainian 5 oligarchs. So there was, you know, a lot of open 6 source public information pointing towards the 7 possibility that the Russians had infiltrated the 8 Trump campaign. So we spoke broadly to reporters 9 and encouraged them to look into this.10 Q. And did you ever come to find out who the11 journalists had spoken with at the FBI about the12 existence of an investigation into Russian13 interference and possible ties to the Trump14 campaign?15 A. No.16 Q. So you had indicated that Mr. Steele said17 he had -- I think your phrase was "broken off" with18 the FBI. What did you understand that to mean?19 A. That Chris was confused and somewhat20 disturbed and didn't think he understood the21 landscape and I think both of us felt like things22 were happening that we didn't understand and that23 we must not know everything about, and therefore,24 you know, in a situation like that the smart thing25 to do is stand down.Page 230￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 231 1 Q. And had he been reaching out affirmatively 2 to the FBI and providing them with information or 3 were they reaching out to him and he was simply 4 responding to their requests? 5 A. The first contact was initiated by Chris 6 to someone that he said he knew. 7 Q. And now you're just going back to the July8 contact? 9 A. Yes. The September briefing or debriefing10 in Rome I believe I understood -- to this day I11 understand that to have been initiated by the FBI.12 Subsequent contacts during this period I just don't13 know.14 Q. Do you know if there were any contacts15 after that second meeting in Rome between then and16 the point in time which occurred sometime between17 October 31st and the election day when he stopped18 communicating with the FBI, do you know if there19 actually were any conversations or meetings between20 Mr. Steele and the FBI?21 A. He didn't literally tell me about specific22 contacts. I just recall that there was -- that he23 broke off, which implies that he told him he didn't24 want to have anything more to do with them. I25 believe he also mentioned that they didn't like￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 media coverage, that there was media coverage of,2 you know, FBI interest in Donald Trump. I don't3 know what it was that they didn't like.4 Q. And I think you've already answered this5 question, but to the best of your knowledge, did6 Mr. Steele ever obtain payment from the FBI for7 actual research that he was doing on Russian8 interference or on possible ties between the Trump9 campaign and Russia?10 A. He told me he did not, and I have no11 independent information other than what he told me.12 I don't believe he ever received compensation for13 working on anything related to Trump and Russia.14 Q. I'm going to direct your attention back to15 what we marked as Exhibit 3, which is the series of16 memos that you had received from Mr. Steele in the17 course of his work. We talked about the first memo18 and we also talked about the second memo to some19 degree. You were explaining to me why you believed20 the second memo, which starts at page 41394, came21 about, why he had generated that report or done22 that research, and you had indicated that there was23 much more public reporting on the hacking. I think24 you had mentioned -- that's when you mentioned25 Debbie Wasserman Schultz.Page 232￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 So with regard to that memo, were there any2 particular things that you independently verified?3 A. I just need to review it here for a4 second.5 Q. Sure.6 (Reviewing document.)7 BY THE WITNESS:8 A. Most of this I did not seek to9 independently verify and was relatively new10 information. I was aware at the time of11 connections between Russian intelligence and cyber12 criminals, and I was aware at the time that the13 Russian mafia and Russian cyber crime was a14 subcontractor to the Russian intelligence services.15 So this comported with my general knowledge of16 these matters, but a lot of the specifics was new17 information to me.18 The only things in here that I specifically19 recognize from other work or from other research20 was that the -- the allegation that the telegram21 encrypted messaging system, which is an app, had22 been compromised by Russian intelligence and that23 someone else in the business of cyber security had24 told me that too who was in a position to know. I25 don't remember who that was, but I was told that byPage 233￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 234an American. And issues of Russian criminaloperations with names like Booktrap and Maddel(phonetic) rings a bell to me or did ring a bell tome at the time. There's been a great deal -- therehad been a great deal at this time even of U.S. lawenforcement activity against organized Russiancyber crime operations. Q. And this memo which is dated 26 July -- itactually bears the date 2015. A. I noticed that. Q. Is that just, as far as you understand it,a typo or mistake? Was it actually 2016?A. Yes. Q. Then similarly with what I have -- and I'mjust doing it in the order that it was Bates-stamped and appeared on BuzzFeed -- there's atwo-page report and it bears the Bates Nos. 41397and 41398 and it has a company report number2016/095. This one has the title "Russia/U.S.Presidential Election, Further Indications ofExtensive Conspiracy Between Trump's Campaign Teamand the Kremlin." Did you do any independent verification ofthese facts? A. I did some work on aspects of this. We￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

were separately -- you know, my team and myselfwere separately investigating various things inhere. So I can't talk about this as averification, but I was analyzing this. MR. FOSTER: Speak up, please.BY THE WITNESS: A. I analyzed this information in the samemanner I analyzed the other stuff. Q. So based on the work that you were doing,did any of that independent work that you did alterthe content of this?A. No. Q. So it was in addition to whatever wasprovided in this memo, this two-page memo? A. Yes, that's right. Q. And to the best that you can recall, canyou tell us what you were learning at the same timeabout the topics covered in this memo? A. Yes. Could I just clarify something? Iassume this is exactly how it was published andsomeone mixed up the sequence of the memos. So thenext memo's numbered 94 and is dated July 19th andthis one is 95 and is not dated, I don't believe.Maybe that's why they got mixed up. But in any event, what I would loosely callPage 235￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 236 1 the Carter Page memo came before this conspiracy 2 memo. So with that caveat I can say we were 3 investigating just based on open sources and, you 4 know, other methods, more public information Carter 5 Page's trip to Russia. We watched tapes of it, we 6 did background work on Carter Page, I did research 7 on his business dealings, and in the course of 8 trying to analyze -- you know, this is some new 9 detail here about how the operation is working in10 the Kremlin and how they are trying to use11 influence and it comports with my knowledge and12 Chris's knowledge of how the Kremlin does this,13 which is they offer people business deals as a way14 to compromise them. And, in fact, you know, to my15 knowledge, this is a much bigger issue than16 personal indiscretions when it comes to the way the17 Kremlin operates and is something I know a fair bit18 about.19 So we looked into Carter Page and we also20 looked into Igor Sechin and whether Sergei Ivanov21 was in a position to be managing the election22 operation, which is what 94 talks about, and we23 determined that he was. I, you know, independently24 verified he does have a deputy who's very obscure25 named Igor Divyekin. It's spelled two different￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

ways here. I believe the correct spelling isD-I-V-Y-E-K-I-N. MR. MUSE: Can you give the Bates number ofthe document you're looking at. MR. SIMPSON: This one is 41399.BY MS. SAWYER: Q. And just for the record, it's a two-pagedocument, 41399 to 41400, and it has the date, Ithink you indicated before, 19 July 2016. Is thisthe memo that you said you referred to as theCarter Page memo?A. Yes. Q. And you were explaining that in thesequencing this one came before the document thatactually in terms of Bates numbers --A. Right. Q. -- comes before it which we had talkedabout which had the company report No. 095. So 94came to you before 095 -- report No. 095; is thatcorrect? A. That's my recollection. Q. So with regard to the research you werealso doing, is it also just true that whateverindependent research you were doing did not thenget incorporated into document company reportPage 237￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 238 1 2016/94, the Carter Page memo? 2 A. That's correct. We essentially segregated 3 this reporting from other things we were doing for 4 reasons we discussed earlier. A lot of this is 5 human intelligence, it's not the kind of thing that 6 you would share with almost anyone basically. A 7 lot of the work that we do is public record 8 research. Generally speaking, most of this 9 information is useful for making decisions and10 trying to understand what's going on, but it's11 not -- doesn't have much use beyond that unless you12 can independently verify it. So our reports are13 full of footnotes and appendices and court records14 and that sort of thing.15 Q. So is it fair to characterize the research16 that you were doing as kind of a separate track of17 research on the same topic sometimes?18 A. I think so. I wouldn't say it was19 completely separate because, for instance, on some20 subjects I knew more than Chris. So when it comes21 to Paul Manafort, he's a long-time U.S. political22 figure about whom I know a lot. But his23 reporting -- you know, so there may have been some24 bleed between things I told him about someone like25 Manafort, but most of these characters neither of￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 239 1 us know much about and it's really just he's 2 faithfully reporting information to him that's 3 being reported to him by his network. 4 In British intelligence the methodology's a 5 little different from American intelligence. 6 There's a practice of being faithful to what people 7 are saying. So these are relatively 8 straightforward recitations of things that people 9 have said. Obviously as we talked about before,10 you know, disinformation is an issue that Chris11 wrestles with, has wrestled with his entire life.12 So if he believed any of this was disinformation,13 he would have told us.14 Q. And did he ever tell you that information15 in any of these memos, that he had concerns that16 any of it was disinformation?17 A. No. What he said was disinformation is an18 issue in my profession, that is a central concern19 and that we are trained to spot disinformation, and20 if I believed this was disinformation or I had21 concerns about that I would tell you that and I'm22 not telling you that. I'm telling you that I don't23 believe this is disinformation.24 Q. And then on the memo, the Carter Page25 memo, which is company report 2016/94, you said￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 240 1 that you had done -- you, Fusion -- you, Glenn 2 Simpson had done some research into Carter Page, 3 including Mr. Page's business dealings?4 A. Yes. 5 Q. Is that information that you still have? 6 A. I don't know. I haven't looked for it. I7 don't know. 8 Q. You also specifically mentioned Igor 9 Sechin and maybe work that you had done research10 into Sechin. Is that work that you would also11 still have?12 A. I don't know if I have anything specific13 on Sechin. Sechin is a well-known character. I14 collect, you know, research on various people who15 are oligarchs or mafia figures. I don't think I16 have any specific reports on Sechin, but I know a17 lot about him. He's, you know, sort of Putin's18 No. 1 compadre in the kleptocracy.19 Q. And with regard to Carter Page, did you20 reach any findings, conclusions about his business21 dealings, about him, about his connections in22 particular to, you know, Russia?23 A. Yes.24 Q. And can you share what those were?25 A. Carter Page seemed to us to be a typical￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 241 1 person who the Russians would attempt to co-opt or 2 compromise or manipulate. He was on the younger 3 side, a little bit -- considered to be a striver 4 who was ambitious and not terribly savvy, and those 5 are the kind of people that the Russians tend to 6 compromise. That was the general sense we had. He 7 was also, you know, from early on described as 8 somewhat eccentric. 9 There was a -- I remember quite clearly there10 was a bit of a -- when we were talking to reporters11 about him because he was all over the news for this12 trip to Russia and we had done -- there was a fair13 amount of open source on his consulting firm, his14 complaint that he'd lost money on Russian15 investments and he owned stock in Gazprom and he16 was really mad about the sanctions and he went over17 there in this hastily-arranged trip to speak to18 this school and that was all pretty unusual, but19 there's a lot of skepticism in the press about20 whether he could be linked between the Kremlin and21 the Trump campaign because he seemed like a zero, a22 lightweight.23 I remember sort of not being able to kind of24 explain to people that's exactly why he would end25 up as someone who they would try to co-opt. Of￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 course, you know, when we talk about things in the2 dossier that are confirmed, this is one of the3 things that I think really stands out as notable,4 which is that Chris identified Carter Page as 5 someone who had -- seemed to be in the middle of 6 the campaign, between the Trump campaign and the 7 Kremlin, and he later turned out to be an espionage 8 suspect who was, in fact, someone that the FBI had 9 been investigating for years.10 Q. So beyond what is in the dossier, did you11 kind of find any evidence that he had actually been12 compromised? Now I'm speaking of Carter Page.13 A. Well, the definition of compromised is14 someone who has been influenced sometimes without15 even their knowledge. We had reason to believe16 that he had, in fact, been offered business deals17 that were -- that would tend to influence him,18 business arrangements.19 Q. And do you have the records of those20 business deals that you had collected?21 A. Yeah. I don't think so. Most of that22 was, in fact, reporting that we did with other23 people who knew him from the business world.24 Q. And then just the next memo that we had25 touched on, 2016/95, it has Bates numbers 41397 toPage 242￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

398, it does not bear a date on it. Do you recallroughly when you received this particular report? A. Sometime in midsummer. Q. The next report, which is 2016/097 whichis two pages, has the date of 30 July 2016. Justby the numbers it would appear to maybe have comebetween those two. Does it seem logical that itcame sometime between July 19th and July 30th? A. That seems logical. Q. And then just in general, with regard tothis particular memo did you do any research toverify this information that was in this memo? MR. LEVY: Beyond what he said as a generalmatter? MR. MUSE: I'm sorry. You were going backand forth. Which one in particular? MS. SAWYER: This is memo No. -- it hasCompany Intelligence Report 2016/095, it's Batesnumbers 41397 and 41398. MR. MUSE: Thank you.BY MS. SAWYER: Q. Was there particular information in thismemo that you did verify? A. One of the things I did, which is prettytypical of how I would sort of analyze things, wasPage 243￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 244 1 I looked at the Russian pension system to determine 2 if, in fact, the Russian government was 3 distributing lots of pension payments to Russian 4 immigrants in the United States, and I found some 5 reports from the Social Security Administration and 6 other places describing this system. 7 Basically because everyone in Russia, you 8 know, more or less works for the government, 9 there's a lot of -- there's a large number of10 Russian emigres in the United States who receive11 pension payments that are paid through the12 embassies and various people, Russian lawyers and13 others who we became interested in in the course of14 this investigation seem to be involved in that15 process. I'm not saying they did anything illegal.16 I'm just saying, you know, we looked at this17 system, and as someone who does a lot of money18 laundering work this was an interesting thing that19 I hadn't heard about.20 There's all this money flowing in the United21 States from Russia, it probably flows in under some22 sort of diplomatic status. So if there's sanctions23 on Russia and the Russians can't move money in the24 United States for most things, this would, in fact,25 be an ideal mechanism for moving money into the￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 United States for whatever purpose, for some kind2 of illicit purpose. I think that's a pretty good3 example of the kind of general work I would do to4 determine whether there's some base level of5 credibility to the things we're getting.6 Q. And in answering that you said that some7 of the officials that you had identified as8 involved in this effort seemed to come up with9 regard to the pension disbursements. Who10 specifically are you referring to?11 A. We identified a lawyer in Sunny Isles12 Beach, Florida who said she previously worked for13 Gazprom and just had on her professional Website or14 someplace that she was -- she had some kind of15 relationship with the Russian embassy in dealing16 with these pension issues.17 Q. And do you recall that lawyer's name?18 A. I don't.19 Q. Anyone else besides that individual?20 A. If I could look at this for a second.21 Q. Sure.22 (Reviewing document.)23 BY THE WITNESS:24 A. I don't have a clear recollection of this.25 I'm sorry. I thought there was another name inPage 245￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 here that we had looked at, but I don't see it in2 this memo.3 Q. To the extent you have records about this4 and the individual in Sunny Isles, would you at5 least look for them and let us know whether you6 would be willing to provide them to the committee?7 MR. LEVY: Counsel has the request.8 BY MS. SAWYER:9 Q. Just moving on to the next memo, which is10 Company Intelligence Report 2016/097, it bears the11 Bates Nos. 401 and 41402, it's a two-page memo12 dated 30 July 2016. Again, when you take a look at13 that, was there anything that you independently14 verified that comes out of this memo?15 (Reviewing document.)16 BY THE WITNESS:17 A. I don't think so.18 Q. Okay. Then Company Intelligence Report19 2016/100, was there any information there that you20 either independently verified or had independent21 research on any of the individuals mentioned in22 there? It mentions Sergei Ivanov, Dmitry Peskov.23 MR. MUSE: If I may, some clarification.24 When you say is there anything that you25 independently verified that comes out of the memo,Page 246￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 247 1 are you talking -- it's a little confusing because 2 the memo comes in, he already knows some 3 information, but I think he's generally said that 4 he's not doing a draft of the memo beforehand and 5 yet your question seems to permit that possibility. 6 MS. SAWYER: No. I appreciate the 7 clarification. 8 BY MS. SAWYER: 9 Q. Just to be clear, I'm not trying to --10 what we're trying to determine is is there11 information that either you had in your possession12 that corroborated and verified this or even went13 beyond what was in this and amplified information14 on any of these individuals relevant to Russia's15 interference or possible ties with the Trump16 campaign?17 A. Yes. I'm trying to be as helpful as I18 can. The thing that we worked on with regard to19 Sergei Ivanov, who was the head of what's called20 the head of administration which we confirmed from21 open sources is kind of an internal Kremlin22 intelligence operation, and that Ivanov according23 to experts on Russia, the Russian military, Russian24 intelligence, does, in fact, run this internal25 Kremlin intelligence operation that sort of sits￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 248 1 atop the FSB and the SVR, the GRU, which are the 2 other agencies specifically tasked with areas of 3 intelligence, military for the GRU, foreign for the 4 SVR, domestic for the FSB. 5 Before I got this memo I didn't know about 6 this internal Kremlin structure. It was either 7 this one or the previous one. So in the course of 8 saying who is this Ivanov guy, you know, we looked 9 at Ivanov and found journal articles and other10 public information about his long history of11 intelligence. He's a veteran of the FSB, his long12 history with Vladimir Putin, and his role atop this13 internal operation.14 In particular I remember reading a paper by a15 superb academic expert whose name is Mark Galeotti,16 G-A-L-E-O-T-T-I, who's done a lot of work on the17 Kremlin's black operations and written quite widely18 on the subject and is very learned. So that would19 have given me comfort that whoever Chris is talking20 to they know what they're talking about.21 Q. With regard to that just in general, I did22 want to ask you not to identify based on the23 particular sources, but did Mr. Steele ever share24 with you who his sources were?25 MR. LEVY: That conversation, if it occurred,￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 249 1 would implicate obligations and he's going to 2 decline to answer that question. 3 MS. SAWYER: And is that based just on the -- 4 can you just articulate the obligations so we can 5 understand them. 6 MR. LEVY: It's a very sensitive security 7 issue and I just don't -- in a transcript where 8 there's no assurance of confidentiality it's not a 9 discussion we want to have here.10 BY MS. SAWYER:11 Q. And do you know whether he shared his12 sources with the FBI?13 A. I don't. I don't know.14 MR. FOSTER: What was the answer?15 MR. SIMPSON: Sorry. I don't know whether he16 shared his sourcing with the FBI.17 MS. SAWYER: Can we just take a minute. We18 can go off the record for a minute.19 (A short break was had.)20 MS. SAWYER: Just with sensitivity toward the21 lateness of the day and in the interest of time it22 would just be helpful -- and I'll give you as much23 time as you need to take a few minutes and, if you24 could, look through the remaining memos and let us25 know if anything kind of stood out to you, if there￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC

Page 250were things that either did not ring true at thetime and that you were concerned about or things inparticular that in addition to what's in here youhad independent research about that you could sharewith the committee in the context of ourinvestigation. Is that a clear request? MR. MUSE: Heather, may I make a suggestion? MS. SAWYER: Sure. MR. MUSE: Why don't we break for a fewminutes so he can look at it, but here's a biggerproblem and I don't mean this as criticismparticularly with regard to the sensitivity as totime. The difficulty is in summary questionsthere's sometimes the problem that is created whenyou try to sort of do a wholesale commentary,particularly after it's been sort of morefocused -- MS. SAWYER: I understand where you're going.So yeah. I don't want to put us in a positionwhere -- MR. LEVY: Let's just take some time for thewitness to review the document. MS. SAWYER: Why don't you take a little bitof time. MR. MUSE: In that spirit maybe you could1-800-FOR-DEPOwww.aldersonreporting.com

1 look in case you have a more focused inquiry too.2 MS. SAWYER: We can certainly do that. Why3 don't we take a five-minute break and I'll ask4 whatever remaining questions we have on the5 dossier. 6 MR. FOSTER: We'll go off the record at 5:11. 7 (A short break was had.) 8 MS. SAWYER: We're back on the record at9 5:20.10 BY MS. SAWYER:11 Q. We appreciate you are walking through some12 of these and we understand your general practice13 and I want to make sure I'm characterizing this14 accurately. When you would get the memos you15 would -- from Mr. Steele you would review them, you16 would see if they resonated with information that17 you already knew and other research you may already18 have done. I think you already told me that you19 don't recall at the time anything jumping out at20 you as patently inaccurate; is that fair to say?21 A. Yes, that's fair to say.22 Q. And I had just asked you to review and I23 appreciate you taking the time to review the24 additional memos which would just run from Bates25 No. 41405 to 41425 to just try to determine for thePage 2511-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425committee if research that you had been doing onthe separate track on some of these topics inparticular amplified the work in the dossier. MR. LEVY: When you say "amplified the workin the dossier," what do you mean? MS. SAWYER: Both kind of verified and maybegave you some additional information and insightson either the factual allegations in them orwhether or not the key players identified had alsoengaged in either similar or related behavior onRussian -- you know, related to Russianinterference.BY THE WITNESS: A. I'd say that's generally right. I read alot of books and studies on Russia and organizedcrime. So over the years I just have a lot ofresidual knowledge of some of the people andsubjects that are covered in the memos. Q. Okay. So nothing certainly jumped out atyou and then as -- A. Nothing jumped out at me -- Q. -- as inconsistent with information thatyou had gained from other sources? A. That's correct. Q. And did you have any reason to believePage 252￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425either then or now that Mr. Steele would have kindof fabricated any of the information that heincluded in any of these memos?A. No. Q. I do want to return to a few of the topicsand a few of the specifics, but I think I'll holdthat until the next round because I have a fewother just follow-up questions for you. It had come up in the last round that therewas a meeting and some information was provided toMr. Kramer. Were you still -- at the time thatoccurred were you, Fusion GPS, still working onbehalf of a client who had engaged you to doresearch as part of the presidential electioncampaign or did that occur after that engagementended? A. It occurred after the engagement hadended. Q. And besides Mr. Steele, did you discusssharing information with Mr. Kramer with anyoneelse? A. Not that I recall. Q. My colleagues had also asked you aboutmeetings and particularly that occurred betweenJune 8th and June 10th of 2016 and some of thePage 253￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Page 254individuals involved in those meetings. As ageneral matter, did you discuss the work you weredoing related to the presidential election campaignwith -- did you ever discuss that with NataliaVeselnitskaya? A. I don't believe I ever discussed it withher. I'd just add that she doesn't speak muchEnglish. So the possibilities are almost none. Ididn't discuss it with her. Q. Do you have any reason to believe that sheknew that you were doing work -- oppositionresearch work on then Candidate Trump?A. No. Q. Do you have any reason to believe that sheknew that Christopher Steele was doing work for youas part of that project, the opposition research onCandidate Trump?A. No. Q. What about Rinat Akhmetshin, did you evertalk with Rinat Akhmetshin about the fact that youwere doing opposition research on Candidate Trump? A. Not that I recall, no. Q. Do you have any reason to believe thatChristopher Steele ever spoke with Rinat Akhmetshinabout the fact that Christopher Steele had been￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 engaged by you to do work -- related to the 2 opposition work on then Candidate Trump? 3 A. Do I have any reason to believe that he 4 spoke? No, I have no reason to believe he did. 5 Q. Do you know if he did or not? 6 A. It's never -- we've never discussed it, 7 but I have no reason to think he would have. 8 Q. And if he had discussed it, would that 9 have been consistent with the nondisclosure10 agreement that you indicated you would have had11 with Mr. Steele?12 A. That would -- if he discussed it with13 someone like that without my knowledge, it would14 not have been consistent with our agreement.15 Q. And then given that, would it surprise you16 if Mr. Steele had talked with Rinat Akhmetshin17 about the work he was doing related to then18 Candidate Trump?19 A. Yes, that would surprise me.20 Q. Did you discuss the fact that you were21 doing opposition research on Candidate Trump with22 anyone at Prevezon Holdings?23 A. Not that I recall, no.24 Q. And if you had done so, would that have25 been consistent with your confidentialityPage 255￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425obligations to that client? A. No, it wouldn't have been consistent. Q. Did you speak with anyone at BakerHostetler about the work that you had been engagedto do on then Candidate Trump? A. Not that I recall. Q. So the point in time at which you were inmeetings that included -- the meetings that you hadrelated to the Court hearing at Prevezon thatyou've already discussed, the dinner, the Courthearing, and then a subsequent dinner, they occurright around the same time that NataliaVeselnitskaya and Rinat Akhmetshin and theindividual you described as a translator, AnatoliSamochornov, met -- or it has been reported metwith individuals in the Trump campaign. Did thattopic just never come up during those three days? A. It never came up. I don't know what elseto say. It never came up. Q. So you at the time had no idea that theywere meeting with or met -- and actually, in fact,met with members of the Trump campaign? A. I didn't have any idea about that meetinguntil quite recently. Q. So in an August 1, 2017 news briefingPage 256￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼ 1 White House Press Secretary Sarah Huckabee Sanders 2 said "The Democrat linked firm Fusion GPS actually 3 took money from the Russian government while it 4 created the phoney dossier that's been the basis 5 for all of the Russia scandal fake news." What is 6 your response to that statement? 7 A. It's not true? 8 Q. And what in particular is not true about9 it?10 A. Well, it's a false allegation leveled by11 William Browder before this committee and in other12 places for the purpose of his advantage. She's13 repeating an allegation that was aired before this14 committee and in other places that we were working15 for the Russian government and it's not true.16 Most importantly the allegation that we were17 working for the Russian government then or ever is18 simply not true. I don't know what to say. It's19 political rhetoric to call the dossier phoney. The20 memos are field reports of real interviews that21 Chris's network conducted and there's nothing22 phoney about it. We can argue about what's prudent23 and what's not, but it's not a fabrication.24 Q. And I think you've already answered you25 contend that you were not taking money from thePage 257￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 Russian government and that was in relation to the2 litigation work you had done with Baker Hostetler,3 correct?4 A. Yes. They are a well-regarded law firm 5 that has obligations to determine the sources of 6 funds when they take a client and, to my knowledge, 7 they did so and the money was not coming from the 8 Russian government. 9 Q. So that was for the Prevezon work for10 Baker Hostetler. Did you take money in any way,11 shape, or form that could be attributed to the12 Russian government for the work that you were13 doing -- the opposition research work that you were14 doing on then Candidate Trump?15 A. No.16 Q. Did, to the best of your knowledge,17 Mr. Steele take money in any way, shape, or form18 that could be attributed to the Russian government19 for the work that he did on the memos as part of20 the opposition research on Candidate Trump?21 A. No.22 I'll add one more thing to the response to23 Sarah Huckabee Sanders, which is her assertion that24 we are a Democrat linked opposition research firm.25 I think I addressed this earlier, but to be clear,Page 258￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Page 259we don't have a business of -- we're not anappendage to the Democratic party. We run acommercial business, we're all ex-journalists. Wetake clients from both sides of the aisle. We havea long history of that, I'm proud of that. I'mhappy to say I have lots of Republican clients andfriends. Q. To the extent there have been allegationsor indications that the work that Mr. Steele did,his research into Russian interference in the 2016election, or your work could have been influencedby Rinat Akhmetshin, do you believe that is trueand if -- do you believe it's true?A. No. Q. Do you believe that the work thatMr. Steele did on Russian interference and possibleties to the Trump campaign or your work could havebeen influenced by Natalia Veselnitskaya?A. No. MS. SAWYER: I think my time is up for thisround. So I appreciate your patience and we'lltake a break. MR. FOSTER: It's 5:34. (A short break was had.) MR. DAVIS: We'll go back on the record.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 It's 5:43 p.m.2 EXAMINATION3 BY MR. DAVIS:4 Q. Mr. Simpson, could you walk us through5 your itinerary to the best you remember it from6 June 8th through 10th of 2016, especially any7 interactions you had with Prevezon team members8 during those three days?9 MR. LEVY: Beyond what he's discussed today?10 MR. DAVIS: Yes.11 BY THE WITNESS:12 A. I took the train to New York. I don't13 recall, but I may have had other business. I don't14 remember. I think there was a dinner. I went back15 to my hotel, went to bed. Got up the next morning.16 I don't remember the sequence, but I remember17 meeting with Weber Shandwick, the PR firm, about18 preparations for -- I think we expected there was19 going to be a trial. I think that's what it was20 about. It might have been about the press coverage21 of the hearing. I just don't remember. I went to22 the hearing and I think -- if I remember the23 sequence correctly, I went to the hearing, then I24 had the meeting with those guys, the Weber25 Shandwick guys, and then I hightailed it home. MyPage 260￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 261 1 son's junior prom was that night or senior prom and 2 I was under some pressure to go home and be a dad. 3 Q. And then on the 10th, that first day back4 in D.C.? 5 A. I don't think that was my first day back. 6 I was back the evening of the 9th. 7 Q. Sorry. The first full day. 8 A. I think it was a weekend. So I don't know 9 what I was doing. Probably just relaxing. I went10 to the dinner, it was at a restaurant called11 Barcelona up on Wisconsin Avenue, it was a social12 occasion. I brought my wife, other people brought13 their wives. We talked about books and other other14 nongermane topics. It was just a social15 occasion.16 (Exhibit 6 was marked for17 identification.)18 BY MR. DAVIS:19 Q. I'm going to show you an exhibit. I think20 we're on 6. We understand these are meeting notes.21 Do these phrases about -- including Mr. Browder22 mean anything to you or relate to any of the23 research that you conducted or otherwise aware of24 regarding Mr. Browder?25 MR. LEVY: When say "meetings notes," meeting￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425notes about what meeting? MR. DAVIS: These are the meeting notes fromthe June 9th meeting at Trump Tower. These areMr. Manafort's notes or they're contemporaneous.BY THE WITNESS: A. I could tell -- obviously you know whoBill Browder is. Cyprus Offshore, Bill Browder'sstructure, you know, investment -- HermitageCapital, his hedge fund, set up numerous companiesin Cyprus to engage in inward investment intoRussia, which is a common structure, both partiallyfor tax reasons but also to have entities outsideof Russia, you know, managing specific investments.I can only tell you I assume that's what thatreferences. I don't know what the 133 million -- MR. FOSTER: Can I interrupt? And you knowthat from research that you did and provided to -- MR. SIMPSON: Yes. MR. LEVY: Let him finish. MR. FOSTER: -- research that you did andprovided to Baker Hostetler and their client? MR. SIMPSON: Yes. There was a -- I canelaborate a little bit. As part of the researchinto how Hermitage Capital worked we looked atvarious things, their banking relationships, thePage 262￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 263 1 way they structured their investments in Russia. I 2 don't remember how many, but there was a large 3 number of shell companies in Cyprus that were used 4 to hold the investments of individual clients of 5 Hermitage. So one of the things we discovered from 6 that was the likely identities of some of 7 Hermitage's clients. 8 BY MR. DAVIS: 9 Q. Do any of the other entries in here mean10 anything to you in light of the research you've11 conducted or what you otherwise know about12 Mr. Browder?13 A. I'm going to -- I can only speculate about14 some of these things. I mean, sometimes --15 MR. LEVY: Don't speculate.16 BY THE WITNESS:17 A. Just would be guesses.18 Q. Okay.19 A. I can skip down a couple. So "Value in20 Cyprus as inter," I don't know what that means.21 "Illici," I don't know what that means. "Active22 sponsors of RNC," I don't know what that means.23 "Browder hired Joanna Glover" is a mistaken24 reference to Juliana Glover, who was Dick Cheney's25 press secretary during the Iraq war and associated￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425with another foreign policy controversy. "Russianadoptions by American families" I assume is areference to the adoption issue. Q. And by "adoption issue" do you mean Russiaprohibiting U.S. families from adopting Russianbabies as a measure in response to the Magnitskyact? A. I assume so. Q. The information here, is this generallyconsistent with the type of information you orBaker Hostetler were providing about Mr. Browderand his activities? MR. LEVY: Can you repeat that question. MR. DAVIS: Is the information here, to thebest you can decipher it, consistent with theinformation that you and Baker Hostetler and HRAGIwere relaying to other parties about Mr. Browder'sactivities? MR. LEVY: He's just told you that a lot ofwhat's here he doesn't know what it means, hedoesn't have knowledge or recollection as to theseterms. MR. DAVIS: The parts you do recognize.BY THE WITNESS: A. Couple of the items touch on things that IPage 264￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425worked on, Cyprus, Bill Browder. Q. I'm going to jump back to the Russiainvestigation. You'd mentioned before you've hadsome subcontractors that you've worked with longenough that you call them super subs; is thatcorrect?A. Yes. Q. Orbis or Mr. Steele, is that one suchsuper sub in your opinion? A. It's a loose term. We don't have a listof super subs. MR. FOSTER: Is he one of them? MR. SIMPSON: There is no list. So I can'ttell you if he's one of them. He's a reliablesubcontractor who's worked with us in the past andwe've been very satisfied with the quality of hiswork. MR. LEVY: Just to reiterate, I think as youdescribed these super subs earlier loosely, evenwith some of these super subs Mr. Simpson said thathe would talk about clients only on a need-to-knowbasis even with the super subs, so-called.BY MR. DAVIS: Q. Beyond the memoranda prepared byMr. Steele, did Fusion create any other workPage 265￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425product relating to this investigation? MR. LEVY: Which investigation? MR. DAVIS: The investigation into Mr. Trumpand his associates. MR. LEVY: In addition to what? MR. DAVIS: Sorry. The investigation intoMr. Trump and his associates. MR. LEVY: I'm sorry. Just repeat the wholequestion. MR. DAVIS: Sure. In addition to thememoranda compiled by Mr. Steele, did Fusion itselfcreate any other work product as part of thisinvestigation? MR. LEVY: I just want to make sure there'sno confusion. It wasn't Fusion that created thememoranda. MR. DAVIS: Right, but it was a subcontractorgiving it back to Fusion. MR. LEVY: That's correct.BY MR. DAVIS: Q. With that understanding, did Fusion createany work product of its own?A. Yes. Q. And can you describe what type of workproduct that was?Page 266￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 A. I believe I described it before. We do a2 lot of public records research, things that are in3 the news, things that are in court documents. We4 summarize those things and try to document, you 5 know, and attach them to the underlying source6 material. 7 Q. So you create sort of summary memoranda of 8 those documents?9 A. Yes.10 Q. Okay. And to whom is that distributed?11 MR. LEVY: As a general matter?12 MR. DAVIS: Well, within the course of this13 investigation.14 MR. LEVY: Inasmuch as that answer calls for15 client communications the answer might be16 privileged, might touch on obligations Mr. Simpson17 has. So he's not going to answer that question.18 MR. FOSTER: Did you provide work product to19 your client?20 MR. LEVY: Again, the answer to that question21 might implicate privilege or his obligations.22 BY MR. DAVIS:23 Q. Is the version of the Steele memoranda24 that was published by BuzzFeed identical to the25 version that Orbis provided Fusion?Page 267￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425A. To my knowledge, yes. Q. The version published by BuzzFeed containsseveral redactions, not merely the ones byMr. Gubarev, G-U-B-A-R-E-V, that were later added.Were those redactions in the versions Mr. Steeleprovided to you? MR. LEVY: So wait. You're asking about theversion in Exhibit 3? MR. DAVIS: Right. MR. LEVY: And you're asking if theredactions that appear here were delivered toFusion? MR. DAVIS: Right.BY THE WITNESS: A. No. Q. Do you know who added those redactions? A. No. Q. Did any version of the memoranda listsource and subsource names rather than referring tosources anonymously? A. I'm not sure I understand the question. Q. In the version that we have as an exhibitobviously it doesn't give identifying informationfor sources, it says source A, subsources, thingslike that. Was there ever a version that listedPage 268￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 the actual source names rather than substituting2 them?3 A. These are the versions that we received.4 Q. They're what? 5 A. These are the memos that we received. 6 Q. Those are the memos you received. Okay. 7 MR. FOSTER: But he's asking if you received 8 any other memos that listed the sources? 9 MR. LEVY: He did not -- what I think he said10 is that he did not receive any versions of these11 memos that listed the sources.12 MR. FOSTER: Okay. Did you receive any other13 documentation from Mr. Steele that listed the14 sources?15 MR. SIMPSON: I don't want to get into source16 information.17 BY MR. DAVIS:18 Q. Again, I don't want to repeat questions19 that have been asked, but I don't want to20 unintentionally omit anything. Did the version21 provided to the FBI include all source names?22 A. I don't know that there was a version23 provided to the FBI.24 Q. When Mr. Steele first met with the FBI in25 the summer of 2016 do you know if he provided thePage 269￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425first memoranda that he created? MR. LEVY: He's already answered thatquestion.BY THE WITNESS: A. No, I don't know. Q. Do you know if he provided any othermemoranda to the FBI on a rolling basis at all atany point? MR. LEVY: He's answered that question too.BY THE WITNESS: A. I don't know. Q. So I'd like to go back to Exhibit 4, Ibelieve. On page 3, paragraph 18 Mr. Steele'sattorneys are describing the December memoranda andthey state "The Defendants" -- again, that'sMr. Steele and Orbis -- "continued to receiveunsolicited intelligence on the matters covered bythe pre-election memoranda after the U.S.presidential election and the conclusion of theassignment for Fusion." They reiterate this point on Exhibit 5 onpage 4. Request 11 asks "Please state whether suchintelligence was actively sought by theDefendant" -- A. Where are you at?Page 270￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 271 1 Q. Page 4, request 11. It states "Please 2 state whether such intelligence was actively sought 3 by the second Defendant or merely received as 4 presently pleaded." The response they say is "Such 5 intelligence was not actively sought, it was merely6 received." 7 Did anyone -- are you aware of who sent this 8 unsolicited intelligence to Mr. Steele?9 A. No.10 Q. Could you describe his methods of11 compiling the dossier a little more? I think12 before you described field interviews. He seems to13 be talking about unsolicited information coming to14 him rather than information he sought out?15 A. I can try. When you're doing field16 information gathering you have a network of people,17 sources. It's not like a light switch that you18 turn on and off, these are people you work with.19 So they call you and tell you stuff. You know, you20 don't close the window and stop answering phone21 calls, you know, when the engagement ends. So I22 assume this is stuff that came in straggle,23 whatever you call it.24 Q. To the best of your knowledge, did25 Mr. Steele pay any of his sources or subsources in￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425the memoranda for information? A. I don't know. I think there's been alittle bit of confusion I would like to clear up.Some people were saying that he was paying peoplefor information. I don't know whether he does ornot, but that's not basically how I understandfield operations to work. You commission people togather information for you rather than sort ofpaying someone for a document or to sit for aninterview or something like that. That's not how Iunderstand it works. Q. To make sure I understand, are you sayingyou don't pay for particular information, you wouldhave an established financial arrangement withsomeone? A. If he did at all, but I did not ask and hedid not share that information. He did not invoiceme for any such. Q. Did Mr. Steele ever discuss his opinion ofMr. Trump with you? A. We didn't discuss our political views ofMr. Trump, I don't think, at least not that Ispecifically remember, if that's what you mean. Q. That is. If I recall correctly, you said earlier thatPage 272￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425once Fusion had exhausted public documentarysources you turned to Mr. Steele and some othersubcontractors for human intelligence; is thatcorrect? A. Yeah, field intelligence. Q. Would your engagement with your clienthave ended had you not turned to humanintelligence? A. I have no idea. I mean, I can'tspeculate. Q. Well, to clarify, when say you hadexhausted the public documentation, are you sayingyou reached the end of your work or was there stillmore? A. No. It's a broad project, there's lots ofthings going on. We're pulling legal filings andbankruptcies and all sorts of other stuff on allkinds of issues. I was talking about specificlines of inquiry. Q. To the best of your knowledge, do RinatAkhmetshin and Christopher Steele know eachother? A. I don't know. Q. To the best of your knowledge, hasMr. Akhmetshin ever worked with Orbis?Page 273￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425 A. Not to my knowledge. MR. FOSTER: If Mr. Akhmetshin were one ofthe sources in the dossier, would you know that? MR. SIMPSON: I believe he would have told methat by now given the public controversy over thismatter, but he hasn't.BY MR. DAVIS: Q. I'm sorry. Is the "he" -- A. Chris Steele. Q. How often would you say you interactedwith Mr. Akhmetshin during the 2016 electionsseason? A. Infrequently, intermittently. Q. When was the last time you spoke with him? A. I don't remember, but I don't think itwas -- I just don't remember. Q. To the best of your knowledge, was EdLieberman aware of your Trump research project? A. Not to the best of my knowledge. MR. FOSTER: Could you just tell us generallywho else other than your client was aware of theTrump research project as it was going on. Soexcluding your client and excluding yoursubcontractors, who else knew that you were doingit?Page 274￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425 MR. SIMPSON: Journalists. MR. FOSTER: In the summer of 2016? MR. SIMPSON: Yes. MR. FOSTER: And they knew that because youwere telling them about it? MR. SIMPSON: We get calls from journalistswho are working on stories about all kinds ofsubjects and some things we can answer questions onand others we don't. I'm a former journalist, as Ithink you know, and we do lots of different kindsof research and people who are working on a storywill call us and say what do you know about, youknow, Carter Page and we'll say, well, here's thethings that we know. MR. FOSTER: And they're aware you're beingpaid to do that research for a client? MR. SIMPSON: I don't know. Generally that'snot an issue. MR. FOSTER: So my question was who knew thatyou were doing the research, the Trump-Russiaresearch at the time? MR. LEVY: He answered the question. He toldyou he spoke with journalists and told them what hehad found. MR. FOSTER: Right. I was trying to clarify.Page 275￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425My question was whether or not they knew you werebeing paid to do that research. MR. LEVY: He answered that question too andhe said he did not explain that to the journalists. MR. SIMPSON: It's hard to generalize. I runa business, it's a research business. Reportersknow we have clients who pay us to do research.So, you know, I don't remember any specific queriesabout whether we were being paid or not, but Ithink most journalists would assume that someonehad paid us to do research. MR. FOSTER: They knew you were doing a Trumpoppo research project as opposed to a HillaryClinton oppo research project? MR. LEVY: From 2015 through the end of theelection? MR. FOSTER: Can you let the witness answer,please. MR. SIMPSON: The word "they" is extremelybroad. Journalists would call and ask questionsabout specific things and from that they mightconclude that we were doing a Trump oppo project. It's just worth pointing out that in apolitical season all kinds of people are doingresearch on all kinds of things. Some people arePage 276￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 277 1 interested in trade, other people are interested in 2 guns. So you wouldn't necessarily intuit exactly 3 what we were doing. Most people are interested in, 4 you know -- they're interested in the story they're 5 working on. So some people will say, hey, I'm 6 interested in whether Donald Trump gets his ties 7 from third-world countries and they wouldn't ask 8 about anything else. 9 BY MR. DAVIS:10 Q. You mentioned before, if I recall11 correctly, that Fusion was having issues with12 persons attempting to hack it?13 A. That's a current concern, yes.14 Q. When did that concern -- when did you15 first become aware of that concern?16 A. Relatively recently.17 Q. So after the election?18 A. Yes.19 MR. FOSTER: Did you tell journalists that20 you had engaged Mr. Steele in the summer of 2016?21 MR. SIMPSON: I don't specifically remember22 doing that until the fall.23 MR. FOSTER: After the election or before?24 MR. SIMPSON: Before the election.25 MR. FOSTER: Can you remember the context in￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 278 1 which you told them that? 2 MR. SIMPSON: Yes. 3 MR. FOSTER: Can you describe it for us,4 please. 5 MR. SIMPSON: Sure. Essentially there was -- 6 at some point the controversy over the Trump 7 campaign's possible relationship with the Kremlin 8 became, you know, one of the main -- major issues 9 in the campaign and there were things that Chris10 knew and understood to be the case that only he11 could really explain in a credible way, and I12 thought that -- we thought that he should be the13 one that explains them, you know. So we sat down14 with a small group of reporters who were involved15 in investigative journalism of national security16 issues and we thought were in a position to make17 use of him as a resource.18 MR. FOSTER: Do you recall whether that was19 before or after he ended his relationship with the20 FBI?21 MR. SIMPSON: Before.22 BY MR. DAVIS:23 Q. Do you recall what the first published24 article -- when the first published article came25 out that referenced material from the memoranda?￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425A. Not specifically. MR. FOSTER: Earlier you talked aboutevaluating the credibility of the information inthe memoranda that you were being provided byMr. Steele and, by way of summary, you talked aboutyour belief that he was credible and that you hadworked with him before and the information he hadprovided you had been reliable in the past. Didyou take any steps to try to assess the credibilityof his sources, his unnamed sources in the materialthat he was providing to you? MR. SIMPSON: Yes, but I'm not going to getinto sourcing information. MR. FOSTER: So without getting into namingthe sources or anything like that, what steps didyou take to try to verify their credibility? MR. SIMPSON: I'm going to decline to answerthat. MR. FOSTER: Why? MR. LEVY: It's a voluntary interview, and inaddition to that he wants to be very careful toprotect his sources. Somebody's already beenkilled as a result of the publication of thisdossier and no harm should come to anybody relatedto this honest work.Page 279￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Page 280 MR. FOSTER: I'm not asking him to identifythe sources. I'm just asking what steps he took totry to verify or validate the information. MR. LEVY: He's given you -- MR. FOSTER: If he can answer generallywithout identifying the sources, I'd ask him toanswer. MR. LEVY: He's given you over nine hours ofinformation and he's going to decline to answerthis one question. MR. FOSTER: And several others. MR. LEVY: Not many.BY MR. DAVIS: Q. I think you mentioned that you were inLondon when you first heard that someone wasinterested in hiring Fusion to work on the Trumpresearch; is that correct? MR. LEVY: Repeat the question. MR. DAVIS: If I recall correctly,Mr. Simpson said that he was in London when hefirst heard that somebody was interested in hiringFusion to do Trump research?BY THE WITNESS: A. That's my recollection. Q. Were either of the clients on this project￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425not American citizens? A. Were either of the clients on this -- MR. LEVY: Clients on which project?BY MR. DAVIS: Q. Were any clients on the Trump research notAmerican citizens? A. I don't mind answering that if that'sokay. They're domestic clients. MR. FOSTER: You said earlier that theinformation that you gather in your work is ownedby the client, it's not owned by you, and sotherefore you also referenced your nondisclosureagreements and that you felt like if you hadinformation that related to national security orlaw enforcement that the nondisclosure agreementdid not prevent you from disclosing thatinformation to third parties. Is that a fairsummary? MR. LEVY: Wait. You said a lot there.Which third parties are you talking about? MR. FOSTER: Well, to law enforcement. MR. LEVY: I think he's answered thisalready. You're asking him whether it waspermittable under his contractual obligations toreport a crime to the national security community,Page 281￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 282 1 and he said yes, it's fine for him to do that. 2 MR. FOSTER: Right. I'm trying to summarize 3 the previous answer as a premise to my next 4 question. Is that an accurate summary of what you 5 said before? 6 MR. LEVY: Summarizing testimony is dangerous 7 after he's given nine hours of it. If you want to 8 ask him a question, ask him a question. 9 MR. FOSTER: Is there a specific provision in10 your NDA that provides an exception for disclosure11 to law enforcement or intelligence agencies?12 MR. LEVY: I think he earlier didn't talk13 about the contract, but if you want to talk about14 it as a matter of practice what your understanding15 is, go ahead.16 MR. SIMPSON: I don't know.17 MR. FOSTER: My colleague Ms. Sawyer asked18 you earlier about public reports that the initial19 client on the Trump work was a Republican and that20 it's also been publicly reported that later there21 was another client who was a supporter of Hillary22 Clinton. Are you the source for any of those23 public reports?24 MR. LEVY: A hundred percent of what you were25 saying was referring to news articles, right.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Page 283 MR. SIMPSON: I've been asked about this byvarious journals as to what I've heard, whetherthey can report things that they've heardelsewhere, and I have not -- I don't know if you'dclassify that as being a source, but I've beenasked those questions and I've avoiding gettinginto specifics. But I have -- if people haveaccurate information of a general nature like that,I generally would not -- I would confirm things. MR. FOSTER: Sorry. I didn't understand youranswer. MR. MUSE: It's quite clear. MR. SIMPSON: Depends on what you say asource is. If someone calls me and say I hearclient No. 1 was a Republican, then I'd say I don'thave any problem with you writing that. That's notquite the same thing. MR. FOSTER: So you confirm the accuracy ofinformation? MR. LEVY: He didn't say that. MR. SIMPSON: There are certain things thatI've chosen not to deny. You know, generallyspeaking, I deal with a lot of journalists. I'mnot going to mislead people.BY MR. DAVIS:￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 Q. To the extent you can clarify, is it that2 there were two sets of clients, one of whom was3 Republican and one of which was a Clinton4 supporter, or was it one person's whose views5 changed? 6 MR. LEVY: We're not going to get into the 7 identity of clients. As you know, we've agreed to 8 an interview about questions 5 through 13 of the 9 March 24 request. Questions 1 through 4 talk about10 the identities of the clients. The Chair and the11 Ranking Member agreed with counsel for Mr. Simpson12 about the scope of this interview and that question13 is outside of it. In addition, the answer to that14 question would implicate privilege and obligations.15 He's talked to you for nine hours, he's given you a16 lot of information, and he's not going to answer17 questions about identities of clients.18 MR. DAVIS: You've asserted attorney-client19 work product privilege --20 MR. LEVY: There is no such privilege. I've21 asserted the attorney work product privilege, we've22 asserted privileges under the First Amendment,23 we've asserted the attorney-client privilege, and24 we've asserted privileges of confidentiality. It's25 a voluntary interview and he's declining to answerPage 284￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425the question. MR. DAVIS: I understand that.BY MR. DAVIS: Q. So with the Prevezon matter, then, is itcorrect the law firm involved was Baker Hostetlerand the ultimate client was Prevezon, is thatright, while you were working there?A. Yes. Q. So any attorney-client privileges withinthe context of that information would be -- theholder of that privilege is Prevezon; is thatcorrect? MR. LEVY: That's a legal conclusion thathe's not qualified to draw. MR. DAVIS: You don't feel that you can speakto it without their permission? MR. LEVY: Speak to what? MR. DAVIS: To questions that would becovered by attorney-client privilege. MR. LEVY: I'm not sure he's qualified toanswer that question.BY MR. DAVIS: Q. Did you work with any law firms inrelation to the Trump investigation? MR. LEVY: Again, we're not getting into thePage 285￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 286 1 identity of any clients -- 2 MR. DAVIS: I didn't say client. 3 MR. LEVY: I understand. Or their lawyers. 4 MR. FOSTER: I think the issue we're trying 5 to deal with is in order to assess your claims of 6 privilege the committee needs to understand at 7 least as much about the context of the dossier work 8 as it does about the Prevezon work in terms of who 9 was involved. So if there's a law firm involved or10 if he was reporting to a law firm or acting under11 the direction of a law firm, then we need to be12 able to assess whether or not that was in13 anticipation of litigation, whether he was doing it14 by the direction of a law firm in order to assess15 your assertions of privilege.16 MR. LEVY: I understand. We've identified17 our position. We've been talking -- Mr. Simpson18 has been answering your questions since 9:30 this19 morning, it's now 6:15. He's been fully20 cooperative and he's here because the Chair and the21 Ranking Member agreed to a limited scope. The22 questions you're asking are outside of that scope23 and this is part of why appearing at a hearing was24 going to be impossible. Through this agreement25 we're here. He's given you a ton of information.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 287 1 If you want to discuss the privilege with counsel 2 after the interview, you may do so. He's answered 3 a ton of questions today and he's going to decline 4 to answer this last one. 5 MR. FOSTER: The last one was did you work 6 with a law firm on the Trump matter? 7 MR. LEVY: He's declining to answer. 8 MR. FOSTER: There were several points in the 9 interview where you made a point of saying your10 firm is not a Democratic linked firm in reference11 to the Sarah Huckabee Sanders quote. It's been12 publicly reported that you did opposition research13 for a client targeting Mr. Romney in the 201214 election. Obviously we've been talking about the15 Trump opposition research. Have you ever done16 opposition research regarding Mr. Obama?17 MR. LEVY: We're not going to get into18 specific client matters that are outside the scope19 of this interview. He's told you he's represented20 clients on the right and left, but he's not going21 to get into other matters beyond Prevezon and what22 he did in the 2016 election.23 MR. SIMPSON: I did investigate Senator24 Obama's campaign in 2008 when I was working for the25 Wall Street Journal and wrote an article that￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Page 288 caused his campaign chair to resign. The record isreplete -- or the public report of my work isreplete with examples of investigations I've doneof Democrats that resulted in them losing theirelections and being prosecuted. MR. LEVY: At the Wall Street Journal? MR. SIMPSON: Yes.BY MR. DAVIS: Q. Are you party to a joint defense agreementrelated to your Prevezon work? MR. LEVY: He's not going to talk aboutprivileged discussions or agreements, and he'sprobably not qualified to answer anyway.BY MR. DAVIS: Q. Is Fusion GPS paying Cunningham Levy forthe firm's representation of you or as a thirdparty? MR. LEVY: That's privileged also. He's notgetting into payments to his lawyers and it'sbeyond the scope of this interview which has nowgone on for almost nine hours.BY MR. DAVIS: Q. Has Fusion GPS ever offered directly orindirectly to pay journalists to publishinformation?￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425A. No. Q. Are you aware of any Fusion clientsoffering directly or indirectly to pay journaliststo publish information from Fusion? MR. LEVY: While working for Fusion on aFusion matter or as a general matter? MR. FOSTER: Can you let the witness answer. MR. LEVY: Well, if the question's clear hecan answer any question -- MR. FOSTER: I think the question was clear. MR. LEVY: -- within the scope of theinterview -- MR. DAVIS: Are there any of Fusion'sclients offering -- THE REPORTER: Guys.BY MR. DAVIS: Q. I'll repeat the question. Are you awareof any of Fusion's clients offering directly orindirectly to pay journalists to publishinformation from Fusion? A. Not to my knowledge or recollection, no. MR. FOSTER: What was the end date of theTrump engagement? MR. LEVY: He told you he didn't recallexactly.Page 289￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425 MR. SIMPSON: That's not correct. Theelection was the end date. I assume you're askingabout the general election? The election datewould have been the end. MR. FOSTER: So you didn't do any work on theTrump matter after the election date, that was theend of your work? MR. SIMPSON: I had no client after theelection. MR. FOSTER: It's 6:21. Let's go off therecord for a minute. (A short break was had.) MS. SAWYER: We'll go back on the record.It's 6:30.EXAMINATIONBY MS. SAWYER: Q. We appreciate your time today, yourpatience in answering our questions. You've been asked a number of questions justabout -- well, strike that. Were any of the particular factual findingsor conclusions that you reached with regard to theresearch that was being done related to Russianinterference in the 2016 election includingpossible ties to the Trump campaign, were any ofPage 290￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 the factual findings or conclusions influenced in2 any way by the identity of the client for whom you3 were doing that work?4 A. All the questions you've asked I guess5 this one I've not given a lot of thought to.6 Offhand, not that I can think of.7 Q. So you weren't trying to reach a8 particular conclusion based on the identity had9 they asked you to find -- well, strike that.10 I think what I'm trying to get some sense of11 comfort around is to the extent there might be12 concerns that the work being done was driven in a13 direction designed to reach a particular conclusion14 for a client or because of the client's identity15 was that the case?16 A. I think it's safe to say that, you know,17 at some point probably early in 2016 I had reached18 a conclusion about Donald Trump as a businessman19 and his character and I was opposed to Donald20 Trump. I'm not going to pretend that that wouldn't21 have entered into my thinking. You know, again, I22 was a journalist my whole life. So we were, you23 know, trained not to take sides and practiced in24 not taking sides.25 So most of what I do as a research person isPage 291￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 292 1 we try to avoid getting into situations where one's 2 etiology or political views would cloud your work 3 because it's a known hazard, but, you know, I 4 reached an opinion about Donald Trump and his 5 suitability to be president of the United States 6 and I was concerned about whether he was the best 7 person for the job. 8 Q. And given that you had been trained not to 9 allow etiology to cloud your work, it sounds like10 you reached a conclusion and had concerns about11 Candidate Trump. What steps did you take to then12 ensure that your conclusion didn't cloud the work13 that was being done?14 A. Well, to be clear, my concerns were in the15 category of character and competence rather than --16 I didn't have any specific concerns for much of the17 time about his views, which I don't share, but that18 wasn't really the issue. Most of what we do has to19 do with do people have integrity and whether20 they've been involved in illicit activity. So21 those were the things I focused on.22 Q. So the conclusion that you reached, was it23 informed by the research that you were -- your24 personal conclusion, was it informed by the25 research that you were conducting?￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 293 1 A. Yes. We deal in factual information and 2 over the course of this project we gathered lots of 3 facts about Donald Trump. 4 Q. You mentioned that earlier and I think you 5 made clear a number of times in the course of the 6 day that the specific work on Russian interference 7 and possible ties to the campaign that Mr. Steele 8 was doing was one part of that bigger picture, and 9 I did want to ask you about some of that bigger10 picture of the work and get a sense from you, if I11 could, you know, some of the background and12 findings. In particular one of the things you had13 mentioned -- well, you just mentioned right now as14 we were speaking the term "illicit activity."15 What, if any, research did you conduct that gave16 you any concerns about then Candidate Trump and17 potential illicit activity?18 A. I think the thing I cited to you was his19 relationship with organized crime figures, and that20 was a concern.21 Q. And what can you share with us about the22 findings, your findings?23 A. Well, I've tried to share as much as I24 could think of over the course of today. As I say,25 there were various allegations of fraudulent￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 294 1 business practices or dishonest business practices 2 or connections with organized crime figures. In 3 fact, you know, there was numerous others that I 4 can't remember the names of. It was a long history 5 of associations with people accused of involvement 6 in criminal activity. 7 You know, just to reiterate, the facts of 8 these investigations are the facts and we don't try 9 to drive an investigation to any particular10 conclusion, certainly not based on our political11 views. So I think it would be, you know, not12 believable for me to tell you I didn't reach, you13 know, views about Donald Trump's integrity, but,14 you know, those were -- those didn't influence the15 research in terms of the findings. Those were the16 findings.17 Q. You mentioned specifically and I think18 with regard to organized crime particularly ties to19 Felix Sater is one. You indicated a connection to20 Yudkovich Mogilebich, I think it is.21 A. Mogilebich.22 Q. Mogilebich, which we can spell for you.23 Tell me if I have this correct.24 M-O-G-I-L-E-B-I-C-H.25 A. Yes.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425 THE REPORTER: What's the first name? MR. SIMPSON: Semyon, S-E-M-Y-O-N.BY MS. SAWYER: Q. Yudkovich, did I get that -- A. I believe I was probably talking fast andI think I might have made a reference toYanukovych, which is the former president of theUkraine. Q. With regard to any of that work, did youcreate work product based on that work? A. I don't specifically recall what we wouldhave created. Q. And with regard to that work, did youshare any of that information with law enforcementagencies? A. No. I mean, just to reiterate, the onlycontact that, you know, occurred during thisengagement was -- at least to my knowledge, wasChris's dealing with the FBI. Other than that, Idon't remember having any dealings with the FBI. Q. You had also mentioned earlier in the daywork -- that there was an investigation about moneyfrom Kazakhstan? A. Yes. Q. And could you tell me about that and whatPage 295￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 296 1 you investigated and what you learned. 2 A. There was some parallel litigation in 3 New York involving attempts by the government of 4 Kazakhstan to recover money that had been allegedly 5 stolen from Kazakhstan, billions of dollars in a 6 colossal bank failure. The name of the bank was 7 BTA Bank. It's been well established in various 8 courts that the government's allegations are 9 basically true, which is that large amounts of10 money were illicitly removed from this bank,11 laundered across Europe and into the United States12 apparently. Allegedly.13 So there was a civil case, at least one civil14 case in New York involving -- filed by the city of15 Almaty, A-L-M-A-T-Y, against some alleged Kazakh16 money launderers. I don't remember exactly how,17 but we learned that -- it wasn't from Chris. We18 learned that Felix Sater had some connections with19 these people, and it's been more recently in the20 media that he's helping the government of21 Kazakhstan to recover this money. There's been22 media reports that the money went into the Trump23 Soho or it went into the company that built the24 Trump Soho. I can't remember the name.25 Q. So the connection in that instance was to￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Felix Sater and through Felix Sater to --potentially to Donald Trump? A. Yes. It was a company that Felix Saterand Donald Trump were involved in together. Q. And the research you did on that project,was that public source research? Did you have anyother -- did you have human intelligence sources onthat project? A. I think I probably did have some humansources. That's my answer. Q. And did you use subcontractors at all onthat work? A. I can't say specifically whether it was --I remember commissioning some public record-typeresearch on Felix Sater and his history inNew York. Q. Did you feel in the course of that thatyou had uncovered evidence of any criminal activityby Donald Trump? A. In the course of that I don't think so. Ithink my concern was the associations with knownorganized crime figures. Q. And that included Felix Sater? A. Yes. Q. Anyone else in particular?Page 297￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Page 298 A. There were others. MR. LEVY: Beyond what we've discussed today? MS. SAWYER: Yes, beyond what we've alreadydiscussed.BY THE WITNESS: A. Another figure involved in the Trump Sohoproject was a central Asian person named Arif,A-R-I-F, is the last name. The first name isgenerally spelled Tevfik, it's T-E-V-F-I-K. If yousearch under a different transiteration of thatname you can find open source reporting allegingthat he's an organized crime figure from CentralAsia and he had an arrest for involvement in childprostitution. Q. You mentioned as well that you hadreviewed tax bills. Were these specifically DonaldTrump's tax bills? A. They were Trump properties and I believewe may have reviewed some public information aboutestate taxes and things like that. We didn't haveaccess to his tax returns. Q. Did you reach any conclusions based onyour review of his tax bills? I think youmentioned that in connection with trying to assesseither financial connections or his financial￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425standing. Did you reach any conclusions withregard to either of those? A. Yes. I concluded -- we concluded that hisstatements about what individual properties wereworth were greatly exaggerated and at odds with theinformation that he'd supplied, you know, in legalfilings with tax authorities and other records,corporate records. Q. Did any of that indicate anything thatshowed a connection to Russia or the Russiangovernment or Russian officials or Russianoligarchs? A. Not that I can recall. Q. You mentioned as well, you brought upTrump golf courses. What in particular were youlooking into with regard to Donald Trump's golfcourses? A. The original inquiry was into the value ofthe courses, whether he had to borrow money to buythem, whether they were encumbered with debt, howmuch money they brought in, what valuations he puton them, and property tax filings. Q. And in general can you share what findingsand conclusions you reached? MR. LEVY: With regard to?Page 299￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 300 1 2 3 4 5 6 7 8 describe it, you mentioned research on Scotland. I 9 don't know if it was particular properties or10 something with regard to Scotland. Can you just11 describe what that research was.12 A. Sure. He has golf courses in Scotland and13 Ireland and one of the facets of UK or anglo14 company law is that private companies have to file15 financial statements, public financial statements.16 So when you're looking at a guy like Donald Trump17 who doesn't like to share information about his18 company, it's useful to find a jurisdiction where19 he's required to share that information with the20 local government.21 So we went and ordered the records -- the22 financial statements of the golf courses. There's23 also a long-running land use controversy -- I think24 there's multiple long-running land use25 controversies over those properties. We haven't MS. SAWYER: To the work on the golfproperties.BY THE WITNESS: A. A number of them don't make any money.His valuations of the properties are questionable.I guess those would be the main findings.Q. You just mentioned broadly but didn't￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 really touched on this at all, but there were also2 environmental issues that were part of the3 research.4 Q. With regard to the public financial 5 statements, did you reach any conclusions based on6 that? 7 A. That they were not profitable entities. I 8 don't specifically recall. I just remember that 9 these were not doing very well and that he'd sunk a10 lot of money into them and he hadn't gotten a lot11 of money back yet.12 MS. QUINT: You mentioned a couple of times,13 Mr. Simpson, that you had particular familiarity14 with Mr. Manafort and even that you were more15 familiar with him in particular than Chris Steele16 was. In general and it might not be easy to be17 general about it, but what was your focus when you18 had looked into Manafort? What main areas were you19 familiar with?20 MR. SIMPSON: Over the years, originally at21 the Wall Street Journal we learned of his22 relationship with Ukrainian and Russian oligarchs.23 So it was generally continued in that vein. He was24 subject of some litigation over his business25 dealings in New York. There was a lawsuit filed byPage 301￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 302 1 the opposition politician from Ukraine accusing him 2 of involvement in corruption in Ukraine. So as 3 just a -- not for any particular client, but just 4 because these matters are something I follow I had 5 collected those documents. I think there's 6 probably some other litigation that I collected 7 that was in a similar vein. 8 MS. QUINT: And it was all documentary or did 9 you have human sources for your Manafort research?10 MR. SIMPSON: I don't think -- for the most11 part it was just what you call gathering string,12 just accumulating files on people or subjects that13 are of interest.14 BY MS. SAWYER:15 Q. The committee, certain members of the16 committee, the Chairman and Ranking Member along17 with Senators Graham and Whitehouse had sent a18 request for documents and information on July 19.19 I understand your efforts to identify that20 information are ongoing and I know that in response21 to one of my questions about Mr. Page your attorney22 has already said that the request for information23 is pending and being reviewed. I just wanted to24 ask you a couple of questions about some of the25 other individuals that we had identified in that￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Page 303letter and in particular in request No. 6? MR. LEVY: Do you have an exhibit or should Ijust get my copy out? MS. SAWYER: I'm happy to enter it as anexhibit or I can just read the names. I don'tthink there's any reason we need to -- MR. LEVY: Just read the names to move italong, that's fine. MS. SAWYER: I don't think there's anyreason -- there's nothing in this letter to informyour answer otherwise.BY MS. SAWYER: Q. So with regard to Alpha Group, sometimesI've heard Alpha Group, sometimes I've heard AlphaBank. I don't know if they're two distinctentities. Do you know anything about Alpha Bank orAlpha Group with regard to Russian interference inthe 2016 election? A. Alpha Group is not a corporate person,it's not an entity. It's just a collective name.Alpha Bank is a bank. I know a limited amount. Iknow, you know, journalists were working on someissues related to this and they asked us about it,but the information didn't come from us. Q. So you were asked by journalists about it,￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 304 1 but you're saying whatever information you had was 2 not generated by Fusion GPS? 3 A. That's right. I know they're a big player 4 and they have long, deep ties to Vladimir Putin. 5 One of the founders, Pyotr Aven, P-Y-O-T-R, second 6 word Aven, A-V-E-N, was an associate of Vladimir 7 Putin when he was in the mayor's office in Saint 8 Petersburg around the time same that Bill Browder 9 was doing business with the mayor's office.10 They're very powerful politically and economically11 in Russia and they have -- in the tens of billions12 are the assets of the founders and they have all13 sorts of interests. They have epic disputes with14 western corporations, including BP. So people in15 my business tend to just have a lot of16 institutional knowledge about them and, you know, I17 shared my institutional knowledge about them.18 Q. You mentioned other founders. Are those19 other founders Mikhail Fridman and German Khan?20 A. Yes.21 Q. Do you have any information there have22 been reports about potential communications between23 a server at Alpha Bank and potentially servers that24 belong to the Trump organization or Trump -- some25 entity associated with Donald Trump? Do you have￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 305 1 any information about those particular reports? 2 A. That's kind of an open-ended question. I 3 think what I said is we were asked about that and 4 it wasn't -- that information wasn't generated by 5 us and I'm happy to say it's beyond our competence 6 to have generated, but in the course of being asked 7 about it, you know, people gave us information. I 8 don't know what else to say. 9 Q. And what information were you given?10 A. A bunch of data. I mean, we were shown11 like do you know what this would mean, does this12 mean, and it's beyond -- it's really -- it's13 certainly beyond my competence.14 Q. So the data that you were shown, you could15 not draw any conclusions from it?16 A. I did not draw any conclusions from the17 data.18 Q. Another individual that there's been a lot19 of press reporting on is Sergei Millian. Other20 than what -- what, if anything, can you tell us21 about did you conduct any research into22 Mr. Millian? And, if so, what conclusions did you23 reach with regard to Russian interference in the24 2016 election?25 A. We learned from sources that he had￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 306 1 connections to the Trump organization and we did an 2 open source investigation of him. We found a 3 picture of him with Donald Trump and another real 4 estate investor in Florida. We've discovered 5 that's not his real name or at least not the name 6 he came to the United States with and that before 7 he became a real estate broker he was a linguist 8 and translator. Speaking generally, people with 9 advanced training in linguistics are oftentimes10 involved in intelligence matters, but I don't know11 whether he is or isn't. Various reporters became12 interested in him because he was boasting about his13 connections to the Trump organization in the Trump14 campaign. So we got lots of inquiries about who15 was he, was he a spy, you know, that sort of thing.16 Q. And did you make a determination whether17 or not he had actual ties to the Trump campaign?18 A. Well, some of the -- yes. I mean, he19 was -- I think he's Facebook friends with Michael20 Cohen. I'm sorry. It was some social media21 connection. It was either Twitter friends or22 Facebook friends. It was public information. We23 took it from that that they did know each other. I24 guess we gradually learned of Michael Cohen's role25 in the Trump campaign as opposed to in the Trump￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 organization.2 Q. And what did you learn about Mr. Cohen's3 role in the Trump campaign?4 A. We learned that his job included dealing5 with inquiries about Russia and he seemed to get6 all of the serious inquiries, investigative7 inquiries about Russia. He seemed to know a lot8 about that. We learned that he was a very9 intimidating person who had a history of10 threatening reporters with libel suits. We learned11 that he's married to -- his father-in-law is a12 Ukrainian emigre, that he had some Ukrainian13 clients and connections to the taxi industry in14 New York which is heavily populated with Russian15 emigres, and we learned that he was involved in16 some of Trump's projects where there was a lot of17 Russian buyers. The only other thing I can think18 of is that he was also the person who dealt with19 allegations against Mr. Trump from the tabloids.20 Q. And with regard to Trump projects with21 Russian buyers, what specific projects had a number22 of Russian buyers?23 A. I don't specifically remember. Florida24 maybe. I think it was Florida. Sorry.25 MS. SAWYER: Just give us a minute.Page 307￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425Page 308 I think that's really all of our questions.I don't know if there's follow-up that you all had. MR. FOSTER: Just very quickly. I can do itfrom right here. So I asked you -- or you were asked earlierabout representations that you're not -- you don'tsee your firm as being Democrat linked and in myprevious question I asserted that there had beenpublic reports that you had done work, oppositionresearch during the 2012 election aimed atMr. Romney, but I didn't ask you to confirm that.Is that correct? MR. LEVY: Work for clients outside the scopeof the interview is not within the scope of theinterview. MR. FOSTER: It's relevant to his claim thathe's not a Democrat linked firm. MR. LEVY: He's answered that question. He'sgiven you multiple answers to that question andsignificant information in support of his answer tothat question, and that small fact which may or maynot be pertinent is that he's going to decline toanswer because it's outside the scope of thisinterview. MR. SIMPSON: I decline to answer.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼Page 309 1 MR. FOSTER: In some of the questioning in 2 the last round there was some talk of your -- you 3 didn't have a particular aim in your research, you 4 were following the facts wherever they lead. Is it 5 fair to say -- is it a fair description to say that 6 your job was opposition research aimed at 7 Mr. Trump? That's been widely reported and 8 characterized that way. Do you think that's a fair 9 characterization of what your job was?10 MR. LEVY: He's been talking for nine and a11 half hours, a lot of which was describing his work.12 To simplify it in any particular way at this point13 I think is unfair to the witness.14 MR. FOSTER: You weren't hired to find15 positive information about Mr. Trump, were you?16 MR. SIMPSON: To the contrary. I think when17 you're doing research on any subject you're trying18 to figure out what the truth is. So if Donald19 Trump's got a good business record and he's really20 worth billions of dollars, that's important21 information. In fact, you shouldn't be feeding22 reporters stories about how Donald Trump is not23 worth billions of dollars if he's worth billions of24 dollars. So, you know, I think the connotation of25 negativity, I get, you know, where you're coming￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼1 2 3 4 5 6 7 8 910111213141516171819202122232425from, but, in fact, you're just trying to figureout what's true. It's like with the Prevezon case, we weretrying to figure out who's telling the truth, is itour guys or is it Browder. I do my job well and Iget rehired when I give them the right information,when I give them accurate information. So ifDonald Trump turned out to be a great businessman,that's what I would have to tell people. MR. FOSTER: Nothing further from me. MR. LEVY: Before we go off the record, willwe be entitled to a copy of the transcript? MR. FOSTER: You'll be able to review thetranscript and request corrections, make anerrata. MR. LEVY: Will it be kept confidential?We'd like to make a request that it be keptconfidential given the sensitivity of the mattersdiscussed today. MR. FOSTER: Your request is noted. MR. LEVY: Noted, but no decision on it? MR. FOSTER: No decision. MR. LEVY: And upon reviewing the transcript,when will we have that opportunity? MR. FOSTER: We can arrange that off thePage 310￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼￼￼￼￼10111213141516171819202122232425(Whereupon the interview was concluded at 7:04 p.m.)Page 3111 record.2 MR. LEVY: When we do we just reserve the3 right obviously to correct the record or supplement4 it.5 MR. FOSTER: That's why we'd allow you to6 review it.7 MR. LEVY: Thank you very much.8 MR. DAVIS: Nothing further. We're going off9 the record at 7:04.￼￼1-800-FOR-DEPOwww.aldersonreporting.comAlderson Court ReportingGlenn SimpsonAugust 22, 2017Washington, DC￼1 2 3 4 5 6 7 8 910111213141516171819202122232425CERTIFICATE OF SHORTHAND REPORTER - NOTARY PUBLIC I, TINA M. ALFARO, Certified ShorthandReporter No. 084-004220, Certified RealtimeReporter, and Notary Public in and for the State ofIllinois, do hereby certify: That GLENN SIMPSON, whose interview ishereinbefore set forth, was duly sworn by me andthat said deposition is a true record of thetestimony given by such witness. I further certify that I am not counselfor nor in any way related to any of the parties tothis suit, nor am I in any way interested in theoutcome thereof. In witness, whereof, I have hereunto setmy hand this ____ day of __________,2017. _____________________________ Tina M. Alfaro, CSR, CRRPage 3121-800-FOR-DEPOwww.aldersonreporting.com

BY THE WITNESS:A. Another figure involved in the Trump Sohoproject was a central Asian person named Arif,A-R-I-F, is the last name. The first name isgenerally spelled Tevfik, it's T-E-V-F-I-K. If yousearch under a different transiteration of thatname you can find open source reporting allegingthat he's an organized crime figure from CentralAsia and he had an arrest for involvement in childprostitution.

Hillary Clinton is the kindest, bravest, warmest, most wonderful human being I've ever known in my life.

The House Intelligence Committee will release the transcript of its interview with Glenn Simpson, the head of controversial research firm Fusion GPS, The Daily Beast has learned. The transcript could be released as soon as today. Adam Schiff, the committee’s top Democrat, has called for the release of the transcript. Fusion GPS’s co-founder has also called for its release. Fusion GPS is at the center of the Trump/Russia probe. The company has drawn unrelenting criticism from Republicans for its role in putting together a dossier that includes salacious allegations about President Donald Trump and the Kremlin. Hillary Clinton’s campaign paid the firm to research Trump, through campaign lawyer Marc Elias.

House Intelligence Committee Chairman Devin Nunes, R-Calif., is questioned by reporters on Capitol Hill on the ouster of Michael Flynn, President Trump’s national security adviser, in Washington, Tuesday, Feb. 14, 2017. (AP Photo/J. Scott Applewhite)J. Scott Applewhite/APThe House Intelligence Committee on Friday posted the transcript of its November interview with Fusion GPS co-founder Glenn Simpson, whose firm was behind the oppo research project that resulted in the so-called “Trump dossier.”

CHASER: Trump was with that Russian gangster in the VIP section at the 2013 Miss Universe pageant (along with other "Kremlin biggies").

There are a number of striking revelations in the testimony. One of them points to a Russian gangster who ran a criminal enterprise out of Trump Tower and was known to associate with Donald Trump while they were both in Russia. Have we just found the Kremlin’s handler in Trump Tower?

It was political commentator Caroline Orr who spotted the revelation today in Simpson’s testimony transcripts. Simpson pointed to a Russian gangster known as “Taiwanchik” who lived in Trump Tower and ran a high stakes gambling ring out of his apartment there (link). Perhaps more importantly, Donald Trump was seen associating with this gangster during the Miss Universe pageant in Russia in 2013. This is the same event in which Simpson’s company Fusion GPS alleges that the Kremlin sent prostitutes to Trump in the “Pee Pee Tape” incident. So let’s think this through.

What are the odds that a Russian gangster was living in Donald Trump’s New York City home of Trump Tower, running a criminal enterprise out of Trump Tower, socializing with Trump when they were both in Russia, and it was all just happenstance? http://www.palmerreport.com/analysis/ga ... rump/7455/

In an interview with House intel committee, Fusion GPS founder Glenn Simpson claimed the Kremlin tried to eliminate U.S. intel sources after the Trump dossier went public.

Photo Illustration by Elizabeth Brockway/The Daily Beast

Glenn Simpson, the co-founder of opposition research firm Fusion GPS, told Congress in November that the Russian government appeared to “purge” people after his firm’s research on President Donald Trump’s alleged Kremlin connections became public.

It’s one of a host of concerns Simpson shared late last year with members of the House intelligence committee in a closed-door hearing. The committee voted this morning to release the transcript of Simpson’s testimony. One of Simpson’s central arguments was that Trump and his associates appeared to be involved in money-laundering on behalf of Russian oligarchs and organized crime figures.

Trump’s allies have spent the last year working to undermine the credibility of Simpson, his controversial firm, and the dossier he produced—work which was funded in part by Hillary Clinton’s presidential campaign. Those efforts make a lot of political sense, given the eye-popping concerns Simpson shared about the president.

“[I]t gradually reached a point where it seemed like most of the people around Trump had a connection to Russian organized crime or Russia in one way or another,” Simpson said.

But one of Simpson’s most dramatic revelations was that the Kremlin used the publication of his firm’s dossier—which contains salacious and unsubstantiated allegations about Trump—as a pretext for a spate of arrests and killings, Simpson said. He also said some of those people who were purged may have been sources for the American intelligence community.

Simpson made this revelation when Rep. Jackie Speier (D-CA), a member of the House intelligence committee, asked him about sources for the dossier.

“And it appears that one of the sources was mysteriously killed?” she asked.

“That's not my information,” Simpson replied. “I mean there was a series of episodes where people were arrested or died mysteriously that came shortly after the disclosure of the existence of this information. And I do believe there was a bit of an old fashioned purge. And I think that—but to my knowledge, it wasn’t anyone that helped us. [I] think it was more likely people who were taking the opportunity to settle scores or were falsely accused, as often, you know, just like in the old days, and/or were sources of the U.S. Intelligence Community, not us.”

Besides concerns about a purge, Simpson went into great detail about his suspicions that Trump and his businesses had connections to money-laundering.

“I think we saw patterns of buying and selling that we thought were suggestive of money laundering,” he said.

One person Simpson mentioned was an accused Russian organized crime figure named Alimzhan Tokhtakhunov, known as “Taiwanchik.” He allegedly ran organized crime network out of Trump Tower, as ABC News detailed, and is currently on the lam. Simpson

“[W]hen Mr. Trump went to the Miss Universe pageant in 2013, Taiwanchik was there in the VIP section with Mr. Trump and lots of other Kremlin biggies,” Simpson said. “So that kind of thing raised questions with us.”

Simpson said he also saw a pattern of unusual business deals involving Trump properties, especially projects in Panama and Toronto; both projects drew investment of Russian mobsters in a way that “smacks of fraud.”

Simpson specifically pointed to Irish and Scottish Trump golf courses as possible thoroughfares for Russian funds. Simpson explained that the Trump-owned golf-courses in Ireland and Scotland have financial statements that “don't, on their face, show Russian involvement, but what they do show is enormous amounts of capital flowing into these projects from unknown sources [...].” He elaborated that these payments amount to “hundreds of millions of dollars.” Simpson described how this was particularly suspect, considering that golf courses as “sinks” that “don't actually make any money.”

When asked if the Russian government would be aware of the activities of Russian organized crime, Simpson replied that, “Russian mafia is essentially under the dominion of the Russian Government and Russian Intelligence Services. And many of the oligarchs are also mafia figures. [...] And so basically everyone in Russia works for Putin now.”https://www.thedailybeast.com/fusion-gp ... er-release

When asked if the Russian government would be aware of the activities of Russian organized crime, Simpson replied that, “Russian mafia is essentially under the dominion of the Russian Government and Russian Intelligence Services. And many of the oligarchs are also mafia figures. [...] And so basically everyone in Russia works for Putin now.”

Was This Russian General Murdered Over the Steele Dossier?The notorious dossier on Trump that Republicans want to discredit may well have been credible enough in Russian President Vladimir Putin’s eyes to get at least one person killed.

AMY KNIGHT01.23.18 5:08 AM ETThe dossier on Donald Trump compiled by former British intelligence operative Christopher Steele—which made headlines for its salacious, unconfirmed passage about Trump and hookers performing for him in a Moscow hotel room—has been denounced by the president’s people as fake news, of course.

But the document was a mixed collection of information and allegations far more precise than the rumors about compromising sexual activities, and some of what's in it may have unnerved not only Trump, but the Kremlin, where hunting down leaks can take a fatal turn.

During his recently released August 2017 testimony to the Senate Judiciary Committee, Glenn Simpson was asked about sources for the sensational dossier, which Simpson’s firm, Fusion GPS, commissioned. Responding for him, Simpson’s lawyer, Joshua Levy, blurted out a surprising warning: “Somebody’s already been killed as a result of the publication of this dossier.”

In his subsequent November testimony to the House Intelligence Committee, which was made available last Thursday, Simpson denied knowing specific cases of people being killed because of the dossier, but he then noted cryptically that “people literally risked their lives to tell us some of this stuff.”

In fact, there is evidence that at least one Russian was murdered because of Steele’s revelations: Gen. Oleg Erovinkin of Russia’s State Security Service (FSB). On the morning of Dec. 26, 2016, Erovinkin, age 61, was found dead in his car in central Moscow. Life News, known to be a Kremlin mouthpiece, first claimed on its website that Erovinkin had been “killed,” but then quickly changed its story, saying simply that Erovinkin had “died.” FSB investigators were called immediately to the death scene, and news outlets soon reported that Erovinkin had succumbed to a heart attack. There was no more official Russian mention of him.

Erovinkin, who joined the KGB (the FSB’s predecessor) in 1976, had in the mid-1990s worked in the Russian Presidential Administration, where his job was to monitor compliance with security procedures. (He was known as “the keeper of the Kremlin’s secrets.”) He then served under Igor Sechin when the latter was deputy premier and subsequently followed Sechin to Rosneft in 2012, after Sechin became CEO of the state oil giant.

Of all the officials who serve under Putin, Sechin is the most powerful. Erovinkin, as chief administrator at Rosneft, was Sechin’s right-hand man and must have known everything about Sechin's contacts with Americans. Those included the former head of ExxonMobile, now Secretary of State Rex Tillerson. (Sechin once said he felt thwarted by U.S. imposed sanctions that kept him from riding motorcycles in America with his friend Tillerson.)

UKIP leader Nigel Farage, left, walking with former aide George Cottrell, right, in Westminster on the day the United Kingdom voted to leave the European Union in a referendum. Cottrell is facing up to 20 years in jail in the United States after admitting to fraud.The Shady Money Man Tangled Up With Brexit, Russia & TrumpMore importantly, in terms of allegations made by the Steele dossier and currently the focus of multiple investigations in Washington, Erovinkin was in a position to keep track of contacts with Trump advisers in considerable detail.

“Erovinkin was known as 'the keeper of the Kremlin’s secrets.'”Steele wrote in his dossier that “a Russian source close to Rosneft President [sic] Igor Sechin” had confided details of a secret July 2016 meeting in Moscow between Sechin and Trump foreign policy adviser Carter Page. The two had allegedly discussed bilateral energy cooperation between the United States and Russia, along with the lifting of Ukraine-related economic sanctions against Russia. As a quid pro quo, Sechin was said to have offered Page and his associates the brokerage of a 19 percent stake in Rosneft, which was due to be privatized. Page reportedly indicated that Trump, if elected president, would lift sanctions.

Known to be sympathetic to the Kremlin, Page was apparently viewed by the Russian security services as a key object for advancing their interests with Trump. (In 2013, an agent from the Russian Foreign Intelligence Service, SVR, met Page in New York City and engaged in several communications with him as part of a recruitment attempt.)

The Steele dossier mentions that Page also met on this same Moscow trip with Igor Diveikin, an FSB colonel who was at the time a senior official in the Internal Political Department of the Russian Presidential Administration. Diveikin, who had previously served in the Presidential Security Service, the agency with the crucial responsibility of guarding the Russian president, reportedly told Page about compromising material the Russians had on Hillary Clinton and also conveyed to Page that the Kremlin had kompromat on Trump, which Trump should consider in his dealings with Russia.

When questioned by the House Intelligence Committee in November, Page denied knowing either Sechin or Diveikin. But he also claimed that he met with no senior Russian officials while he was in Moscow in July 2016, and that turned out to be untrue.

After Rep. Adam Schiff reminded Page of his July 8, 2016, email from Moscow to members of the Trump campaign saying that he had received “incredible insights and outreach” from senior members of Putin’s administration, Page backtracked. He reluctantly admitted meeting with Russian vice premier Arkady Dvorkovich and also with Andrei Baranov, who is head of investor relations at Rosneft, a top management position that would put Baranov in frequent contact with Sechin. (Significantly, Baranov was awarded a medal “for service to his country” by Putin in March 2017.)

After insisting to the committee that he and Baranov only got together because they were old friends, Page was forced to acknowledge that the two may have discussed sanctions and also the potential sale of Rosneft’s stock, which makes one wonder whether Sechin was at the meeting as well.

The plan to privatize part of Rosneft was not known outside of Rosneft’s top management at this time and it was a contentious issue, as was the proposed purchase by Rosneft of controlling shares in the oil company Basneft, which occurred in October. (The sale of 19.5 percent of Rosneft shares to Qatar and the commodities giant Glencore was announced in early December.)

All of these negotiations were fraught, and the subject of high-level infighting among senior Russian officials.

One who initially opposed both of these transactions was Minister of Economic Development Aleksei Ulyukaev, who was arrested in November 2016 on charges of taking a $2 million bribe from Sechin. It was a classic sting operation, with Sechin in charge, and after a sensational trial Ulyukaev was sentenced in December to eight years in a strict regime labor camp. Sechin had been called to appear as a witness, but refused. In his stead, Page’s friend Baranov appeared to testify against Ulyukaev.

Erovinkin would have known about all these intrigues in great detail, and thus could have exposed not only links to the Trump campaign, but internal corruption—all of which would put him in danger if he were thought to be leaking information.

According to the recent book by British journalist Luke Harding, Collusion: Secret Meetings, Dirty Money, and How Russia Helped Donald Trump Win, Steele denied that Erovinkin was a direct source for his report. But, as Harding told me recently, the information could nonetheless have originated with Erovinkin. (Steele refers to "a senior member of Sechin's staff" as confirming the Sechin-Page meeting to his source.) And even it did not come from Erovinkin, he would have borne responsibility for the leaks, since he was the head of Rosneft’s administration, with security part of his purview. The fatal question ultimately is not what he did, but what he was thought to have done.

While the Ulyukaev case and the Rosneft transactions certainly contribute to the air of conspiracy around Erovinkin’s death, it is more than likely that the Steele dossier did him in.

Although the dossier was not published on the web until two weeks after Erovinkin died, the Kremlin was doubtless aware of its contents well before this. Simpson had conveyed much of the material to American journalists in the autumn of 2016, and, according to the Harding book: “For months, reporters on the national security beat and Moscow correspondents had been working feverishly to substantiate the allegations.”

In fact, the arrests in December of high-level FSB officers responsible for cyber operations were widely assumed to be set off by Steele’s revelations that the Trump campaign had colluded in the Russian cyber attacks against the Clinton campaign that were revealed by U.S. intelligence agencies.

However much Trump’s defenders want to dismiss the dossier as a fake concocted by the president’s enemies, the fallout from it in Russia, including at least one highly probable murder, suggests that much of what Steele reported is fact.https://www.thedailybeast.com/was-this- ... le-dossier